Zane M. Raphael v. Camden Development, Inc.

CourtCourt of Appeals of Texas
DecidedDecember 4, 2024
Docket05-24-00053-CV
StatusPublished

This text of Zane M. Raphael v. Camden Development, Inc. (Zane M. Raphael v. Camden Development, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Zane M. Raphael v. Camden Development, Inc., (Tex. Ct. App. 2024).

Opinion

REVERSE and REMAND, and Opinion Filed December 4, 2024

In The Court of Appeals Fifth District of Texas at Dallas No. 05-24-00053-CV

ZANE M. RAPHAEL, Appellant V. CAMDEN DEVELOPMENT, INC., Appellee

On Appeal from the 193rd Judicial District Court Dallas County, Texas Trial Court Cause No. DC-23-01385

MEMORANDUM OPINION Before Justices Molberg, Nowell, and Kennedy Opinion by Justice Molberg Zane Raphael appeals from the denial by operation of law of his motion to

dismiss under the Texas Citizens Participation Act. He contends he established that

appellee Camden Development, Inc.’s counterclaims for breach of contract and

tortious interference are based on or in response to his exercise of the right to

petition, and that Camden failed to establish by clear and specific evidence a prima

facie case for each essential element of the two claims. Because we conclude the

trial court erred in failing to dismiss the breach of contract counterclaim, we reverse

and remand in this memorandum opinion. See TEX. R. APP. P. 47.4. Background

Raphael alleged in his original petition that he was a resident at a Camden-

owned apartment complex, beginning July 1, 2022. Three weeks after moving in,

his truck was stolen from the residential parking lot, and he reported the theft to

Camden and the Dallas Police Department. Raphael informed Camden it did not

have adequate security, cameras “or any other reasonable measures to prevent

similar incidents as well as protect its residents and their property,” but he alleged,

Camden failed to take reasonable responsive measures. He alleged that, from

August through November 2022, garage break-ins, theft, and property damage

became routine, and Raphael’s garage was broken into at least three times, resulting

in the loss of thousands of dollars of property. Raphael reported each incident to

Camden, which told him to take protective measures, such as locking his garage

door. Despite Raphael taking every reasonable measure he could to protect his

property, he alleged that Camden’s negligence and failure to abide by its obligations

subjected him to repeated break-ins. Based upon these allegations, Raphael asserted

claims for negligence, DTPA violations, breach of contract, common law

fraud/fraudulent inducement, and negligent misrepresentation.

Camden answered and raised several affirmative defenses, including waiver

and release. On September 21, 2023, Camden also filed counterclaims, asserting

that Raphael’s claims were “all expressly covered under the lease,” and it had to

–2– incur attorney’s fees defending against the claims. Camden alleged the parties

agreed in Raphael’s lease that Camden (1) “is not liable to Plaintiff for any injury,

damage, or loss caused as a result of any problem with the performance of any

security-related mechanism”; (2) “did not make any representation or warranty that

any security-related mechanism would not be compromised, circumvented, or

malfunction, or would prevent loss by burglary, theft, or other criminal conduct”;

and (3) “is not responsible for Plaintiff’s personal property (including any vehicles)

resulting from criminal acts of others.” Camden alleged Raphael further agreed in

the lease to maintain renter’s insurance to protect his property and to waive any

insurance subrogation rights or claims against Camden related to losses to his

property. Camden also alleged Raphael encouraged other tenants to take legal action

against Camden that would be a breach of these other tenants’ contracts.

Camden asserted a claim for breach of contract, because, it argued, “as a result

of filing of Plaintiff’s Original Petition, Plaintiff has breached and defaulted on the

contractual lease agreement by seeking damages from defendant for losses covered

by plaintiff’s renter’s insurance, in direct breach of plaintiff’s contractual

agreement.” Camden alleged the breach resulted in damages “in the form of

attorney’s fees and court costs and expenses, as well as loss of the benefits of the

contract(s),” totaling at least $49,000. Based upon its allegation that Raphael

solicited other tenants to take legal action against it, Camden asserted a claim for

–3– tortious interference with contractual relations. Camden sought attorney’s fees

under Chapter 38.001 of the civil practice and remedies code and the “default

provision” of the lease.

A few days after filing its original counterclaims, Camden filed a first

amended counterclaim in which it dropped its tortious interference with contractual

relations cause of action.

On November 6, 2023, Raphael filed a motion to dismiss pursuant to the

TCPA. Raphael contended Camden’s counterclaim was based on or brought in

response to his right to petition because, he argued, it was based on and brought in

response to his original petition. Raphael further argued Camden could not establish

a prima facie case for breach of contract because there was no evidence Camden

performed its contractual obligations, Raphael breached his obligations, or Camden

suffered any damages due to the breach. Regarding this latter point, Raphael

contended attorney’s fees are not recoverable as actual damages, and Camden had

therefore failed to even allege it suffered damages resulting from any breach.

On November 30, 2023, Camden filed a second amended counterclaim and a

response to Raphael’s TCPA motion to dismiss. The second amended counterclaim

differed from its predecessor by including a statement that damages resulting from

Raphael’s breach included “loss of employee manhours related to the naturally

flowing consequences of Plaintiff’s breach,” or alternatively, nominal damages. In

–4– its response to the motion to dismiss, it argued the TCPA did not apply to its breach

of contract claim because the parties “specifically contracted that plaintiff waived

claims against defendant for plaintiff’s personal property.” Camden also argued it

presented evidence establishing a prima facie case for each essential element of

breach of contract.

On December 4, 2023, Raphael filed a reply to Camden’s response to his

motion to dismiss, arguing, among other things, that Camden “has not even

attempted to establish a prima facie case for its tortious interference claim” and had

failed to establish a prima facie case for its breach of contract claim.

After a hearing on the TCPA motion, the trial court did not rule on the motion

within thirty days following the hearing, so it was denied by operation of law.

See TEX. CIV. PRAC. & REM. CODE §§ 27.005(a), 27.008(a). This interlocutory

appeal followed.

Discussion

“The [TCPA] protects citizens who petition or speak on matters of public

concern from retaliatory lawsuits that seek to intimidate or silence them.” In re

Lipsky, 460 S.W.3d 579, 584 (Tex. 2015) (orig. proceeding) (citing TEX. CIV. PRAC.

& REM. CODE § 27.001–.011) (footnote omitted). Its purpose “is to encourage and

safeguard the constitutional rights of persons to petition, speak freely, associate

freely, and otherwise participate in government to the maximum extent permitted by

–5– law and, at the same time, protect the rights of a person to file meritorious lawsuits

for demonstrable injury.” TEX. CIV. PRAC. & REM. CODE § 27.002.

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