8 medlen brief resp

8/13/2019 8 Medlen Brief Resp

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Cause No. 12-0047________________________________________________________________________

IN THE SUPREME COURT OF TEXAS

________________________________________________________________________

CARLA STRICKLAND,

Petitioner

v.

KATHRYN AND JEREMY MEDLEN

Respondents

________________________________________________________________________

On Petition for Review from the Second Court of Appeals in Fort Worth, TexasNo. 02-11-00105-CV

________________________________________________________________________

RESPONDENTS BRIEF ON THE MERITS________________________________________________________________________

RANDALL E. TURNER SONDREA J. KING

SBN: 20328310 SBN: 24003728BAILEY & GALYEN SUSAN BLEIL

1901 Airport Freeway SBN: 14056720

Bedford, Texas 76021 LAW OFFICE OF BLEIL & KINGTel: 817-359-7065 5012 Birch Hollow Lane

Fax: 817-764-6336 Fort Worth, Texas 76132

Email:[email protected] Telephone: 817.680.0228

COUNSEL FOR RESPONDENTS

ORAL ARGUMENT IS REQUESTED

FILEDIN THE SUPREME COF TEXAS12 July 9 P5:24 BLAKE A HAWTHOCLERK
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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Cause No. 12-0047________________________________________________________________________

IN THE SUPREME COURT OF TEXAS

________________________________________________________________________

CARLA STRICKLAND,

Petitioner

v.

KATHRYN AND JEREMY MEDLEN,

Respondents

________________________________________________________________________

On Petition for Review from the Second Court of Appeals in Fort Worth, TexasNo. 02-11-00105-CV

________________________________________________________________________

RESPONDENTS BRIEF ON THE MERITS

________________________________________________________________________

To the Honorable Supreme Court of Texas:

Come now Kathryn and Jeremy Medlen, Respondents in the above-entitled and

numbered cause, and submit this brief on the merits as requested by the Court.

Kathryn and Jeremy Medlen are hereinafter referred to collectively as theMedlens.

Carla Strickland is hereinafter referred to as Strickland.

The Clerks Record will be referred to as CR __.

Carla Stricklands Amended Petition for Review will be referred to as Pet. __;

her Brief on the Merits will be referred to as Brief __.


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TABLE OF CONTENTS

Index of Authorities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Statement of Jurisdiction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .v

Issues Presented. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi

Statement of the Facts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .vii

Summary of the Argument. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .ix

Argument. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

Issue One:

May Texas personal property owners seek recovery for the wrongfuldestruction of their property, where that property has little or no marketvalue? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

Issue Two:

Should this Court accept Stricklands invitation to create an exception thatbars Texas personal property owners from seeking redress in the courts

where their destroyed property was a dog? . . . . . . . . . . . . . . . . . . . . . . . 1

Issue Three:

Did Section 101.106(f) of the Texas Civil Practice and Remedies Code barthe court of appeals from deciding the merits of the Medlens appeal? . . . .9

Prayer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10


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INDEX OF AUTHORITIES

CasesAntonio v. Bailey,

332 S.W.3d 395 (Tex. 2011). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Brown v. Frontier Theatres, Inc.,369 S.W.2d 299 (Tex. 1963). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .ix, 5, 6, 7

City of Tyler v. Likes,962 S.W.2d 489 (Tex. 1997). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .ix, 6, 7

Dunnagan v. Watson,204 S.W.3d 30 (Tex. App. Fort Worth 2006, pet. denied). . . . . . . . . . . . . . . . .8, 9

Franka v. Velasquez,332 S.W.3d 367 (Tex. 2011). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9, 10

Garey Constr. Co., Inc. v. Thompson,697 S.W.2d 865 (Tex. App.Austin 1985, no pet.). . . . . . . . . . . . . . . . . . . . . . . . . 8

Heiligmann v. Rose,81 Tex. 22, 16 S.W. 931 (Tex. 1891). . . . . . . . . . . . . . . . . . . . . . . . . .v, 1, 2, 3, 4, 5

Lucas v. Morrison,

286 S.W.2d 190 (Tex. Civ. App. 1956, no writ). . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Medlen v. Strickland,

353 S.W.3d 576 (Tex. App.Fort Worth 2011, pet. filed). . . . . . . . . . . . . . vi, viii,7

Mission Consol. Indep. School Dist. v. Garcia,253 S.W.3d 653 (Tex. 2008). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Patterson v. Planned Parenthood,

971 S.W.2d 439 (Tex. 1998). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2

Petco Animal Supplies, Inc. v. Schuster,144 S.W.3d 554 (Tex. App.Austin 2004, no pet.). . . . . . . . . . . . . . . . . . . . . v, 3, 4

Porras v. Craig,675 S.W.2d 503 (Tex. 1984). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix


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STATEMENT OF JURISDICTION

The Medlens respectfully submit that this Court should decline to exercise its

discretion to review this case under Texas Government Code Section 22.001. Although

Strickland raises a myriad of arguments to persuade this Court to do so, none of those

grounds presents a compelling reason to grant the petition for review.

First, the Fort Worth court of appeals decision does not conflict with this Courts

decision in Heiligmann v. Rose, 81 Tex. 222, 16 S.W. 931 (Tex. 1891). Heiligmann

specifically stated that special damages are recoverable for the negligent destruction of a

dog. 81 Tex. at 226, 16 S.W. at 932. Other cases cited by Strickland in support of her

argument are inapplicable here because they state only the general rulefor the measure

of damages to personal property, without regard to property that has its primary value in

sentiment.

Second, the Austin Court of Appeals decision in Petco Animal Supplies, Inc. v.

Schuster, 144 S.W.3d 554 (Tex. App.Austin 2004, no pet.), which Strickland repeatedly

contends got it right, is contrary to well-settled Texas property law. Nothing in

Heiligmannor any subsequent case from this Court limits the rights of a dog owneras

opposed to owners of other types of personal propertyto sue only for the market or

pecuniary value of his property.

Third, the court of appeals decision does not create a new cause of action that

allows dog owners to sue for loss of companionship or allow dog owners to recover


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mental anguish damages. TheMedlencourt simply applied existing Texas property law

to elucidate thetypes of damages that owners may seek for the destruction of their dog.

The Medlens respectfully request that this Court decline to exercise its jurisdiction

and deny Stricklands Amended Petition for Review.

ISSUES PRESENTED

Issue One:

May Texas personal property owners seekrecovery for the wrongful destruction of

their property, where that property has little or no market value?

Issue Two:

Should this Court accept Stricklands invitation to create an exception that bars

Texas personal property owners from seeking redress in the courts where their

destroyed property was a dog?

Issue Three:

Did Section 101.106(f) of the Texas Civil Practice and Remedies Code bar the

court of appeals from deciding the merits of the Medlens appeal?


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STATEMENT OF THE FACTS

On June 2, 2009, Kathryn and Jeremy Medlens dog escaped from their backyard

and was picked up by Fort Worth animal control. [CR at 27] Jeremy went to the animal

shelter to retrieve the dog, but did not have enough money to pay the fees. He was told

he could return on June 10 to get the dog. [CR 27] A hold for owner tag was placed

on the cage notifying employees that the Medlens were going to return for him. [CR 27]

On June 6, Carla Strickland, a shelter employee, made a list of animals that were

to be euthanized the following day. [CR 27] She placed the Medlens dog on that list

even though he had a hold for owner tag on his cage. [CR 27] The dog was euthanized

the following day. [CR 27]

After learning that their dog had been destroyed, the Medlens filed suit against

Strickland, alleging that her negligence proximately caused the death of their dog. [CR

27] Their pleadings stated that the dog had little or no market value and could not be

replaced, his intrinsic value was far greater than any market value he may have had, and

that they sought recovery for the dogs intrinsic value. [CR 28]

Strickland specially excepted to the Medlens claim for intrinsic value damages on

the ground that such damages are not recoverable for the death of a dog. [CR 32, 34]

The trial court granted Stricklands special exception and dismissed the Medlens lawsuit

with prejudice. [CR 60] The Medlens timely appealed. [CR 61]


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The court of appeals held that because Texas law permits recovery for the intrinsic

or sentimental value of personal property, the trial court erred in dismissing the Medlens

case against Strickland. Medlen v. Strickland, 353 S.W.3d 576, 581 (Tex. App.Fort

Worth 2011, pet. filed). The court sustained the Medlens sole issue on appeal and

remanded the case to the trial court. Id.

The court of appeals declined to address Stricklands cross-point, stating Because

we have sustained the Medlens sole issue and are remanding the case to the trial court on

that basis, we do not need to reach Stricklands cross-point seeking the same relief of

remand. Id.


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SUMMARY OF THE ARGUMENT

This case has nothing to do with mental anguish damages.

This case does not create a new cause of action in Texas for loss of

companionship after the death of a pet.

This caseplainly and simplyis about whether Texas property owners are entitled

to seek intrinsic damages for the destruction of personal property where that property has

little or no market or pecuniary value. This Court has repeatedly answered this issue in

the affirmative. City of Tyler v. Likes, 962 S.W.2d 489, 497 (Tex. 1997) (proper measure

of damages for damaged personal property with small or no market value was loss in

value to owner); Porras v. Craig, 675 S.W.2d 503, 506 (Tex. 1984) (remand of case to

allow real property owner to present evidence of intrinsic value damages); Brown v.

Frontier Theatres, Inc., 369 S.W.2d 299, 304-05 (Tex. 1963) (personal property owner

entitled to reasonable special value of destroyed property, taking into account feelings of

the owner for such property).


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ARGUMENT

Issue One:

May Texas personal property owners seekrecovery for the wrongful destruction of

their property, where that property has little or no market value?

Issue Two:

Should this Court accept Stricklands invitation to create an exception that bars

Texas personal property owners from seeking redress in the courts where their

destroyed property was a dog?

Issues One and Two are discussed together for brevity and clarity of the argument.

Texas dog owners have had a cause of action when someone negligently kills their

dog for more than a century. Heiligmann, 81 Tex. at 222, 16 S.W. at 932. No case from

this Court has stated otherwise in the 100+ years since Heiligmann was decided.

Nevertheless, Strickland seeks this Courts pronouncement that dog ownersunlike other

property owners in Texascannot seek recovery for the destruction of their property.

Relying on speculative public policy considerations, Strickland asks this Court to

hold that where a dog has little or no market value, its owner has no remedy for its

wrongful destruction. However, doing so would render meaningless this Courts

declaration inHeiligmannthat:


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The law recognizes a property in dogs, and for a trespass and infraction ofthis right the law gives the owner his remedy. The wrong-doer cannotescape the consequences of his acts by saying You have suffered no

damages, for the law implies that some damages result from every illegaltrespass or invasion of anothers rights.

Id.at 225-26, 16 S.W. at 932 (emphasis added).

In Heiligmann, this Court pronounced what is commonly referred to as the true

rule applicable in determining the value of dogs:

It may be either a market value, if the dog has any, or some special orpecuniary value to the owner, that may be ascertained by reference to theusefulness and services of the dog.

Heiligmann, 81 Tex. at 226, 16 S.W. at 932 (emphasis added).

Strickland dutifully recites the above statement of this Court. However, she seeks

to distort Heiligmannsclear language and in doing so, to craft a rule more favorable to

her. Because the courts are charged with adjudicating cases based on the application of

the law to the facts before them, such a broad pronouncement is unwarranted. See, e.g.

Patterson v. Planned Parenthood, 971 S.W.2d 439, 443 (Tex. 1998). Yet Strickland

erroneously concludes that, [I]t is clear that when the [Heiligmann] Court mentioned

special or pecuniary value of a dog to its owner, it was referring to economic value

ascertained by reference to the dogs usefulness or services not value attributed to

companionship or other sentimental considerations. [Brief @ p. 10, n. 11]

A careful reading ofHeiligmann exposes the logical gaps in Stricklands argument.

The facts of that case show that Heiligmann purportedly poisoned the Roses' three dogs.


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Most of the Court's opinion addresses Heiligmann's complaints of jury charge error. The

Court then turns to the sufficiency of evidence to support the jury's verdict awarding the

Roses $25 for the loss of each dog, as well as $75 in exemplary damages.Id.at 225, 16

S.W. at 932. Heiligmann argued that the dogs had no market or pecuniary value to the

owners. This Court rejected Heiligmann's argument and instead considered the Roses'

testimony concerning the value of the dogs to them. One of the dogs barked to alert the

owners when someone approached the house. Mrs. Rose testified that she could have

sold the other two dogs for $5 each, but would not have taken $50 each for them.Id.

The issue before this Court inHeiligmannwas the propriety of the jury's verdict. It

appears that the jury listened to the evidence presented and arrived at a reasonable amount

to compensate the Roses for the loss of their dogs. Here, Strickland contends that the

Medlens are not entitled to seek such remedy because to allow them to do so will have

untold dire consequences.

In so arguing, Strickland relies heavily on the Austin court of appeals decision in

Petco, particularly its discussion of the true rule of the Heiligmanncase, set out above.

With all due respect to the Petco court, its analysis and application of Heiligmann is

misguided. In Petco, the trial court awarded the plaintiff intrinsic value damages after her

dog escaped from a groomer and was run over. 144 S.W.3d at 557. The court of appeals

reversed, holding that underHeiligmann, plaintiffs could only sue for the market value of


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the dog, if any, or some special or pecuniary value to the owner, that may be ascertained

by reference to the usefulness and services of the dog.

The Petco court further concluded that Heiligmannmakes clear that the special or

pecuniary value of a dog to its owner refers solely to economic value derived from the

dog's usefulness and services, not value attributed to companionship or other sentimental

considerations. Id. at 561 (emphasis added).

Both the Petcocourt and Strickland assume that, inHeiligmann,"pecuniary value"

and "special value" have the same meaning, and that the absence of the words "intrinsic"

or "sentimental" in that decision precludes recovery for those types of damages. This

conclusion is wrong. Reading Heiligmann in conjunction with the authorities cited

therein, that case cannot reasonably be interpreted as limiting a dog owners recovery to

only market value or pecuniary damages. In setting out the substantially true rule for

the valuation of a dog,Heiligmannrelied onRamsey v. Hurley, 72 Tex. 194, 12 S.W. 56

(1888). In Ramsey, the Court held that owners of property with no market value could

still seek the intrinsic value of their property by showing what the property was worth to

them. Id.By citing Ramsey in this context, the Court in Heiligmannmeant for special

value to include any intrinsic value the property may have had to the owner because of

any particular circumstance or relation.


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Thus, the plain language of the Courts decision in Heiligmann did not limit

plaintiffs recovery to only those damages based on the dogs usefulness and services.

Although there was evidence that only one of the dogs had a skill that provided some

usefulness or service to the plaintiffs (barking when someone approached the house), the

Court nevertheless permitted recovery for the loss of each of the dogs in excess their

market value. In doing so, the Court observed that although there is no evidence in this

case that the dogs had a market value, . . . the evidence is ample showing the usefulness

and services of the dogs, and that they have a special value to the owner. Pecuniary

damages and special damages are not the same thing; Heiligmann clearly distinguishes

between the two.

More recently, this Court has held that where the property at issue has little or no

market value but has its primary value in sentiment the owner may seek to recover the

reasonable special value of the item. See e.g., Brown, 369 S.W.2d at 304-05. No case

from this Court has stated otherwise in the 100+ years since Heiligmann was decided.

Thus, the decisions of this Court, viewed collectively, establish that the true rule is not

limited to the dogs market or pecuniary value, but also allows for recovery of any

reasonable special value the dog may have had to its owner.

By way of example, consider this scenario: What if the property that was destroyed

was the taxidermied body of a dog? The stuffed body almost certainly has no market

value, and, being dead, presumably has no value from usefulness or services so as to


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assign a pecuniary value. Yet Texas law would permit the owner to sue for special

damages for the destruction of this property. Brown, 369 S.W.2d at 304-05. So what

reasonable application of the law allows a suit for damages for the loss of inanimate

personal property but not the destruction of the same property while it is alive?

To circumvent this absurd result, Strickland impermissibly narrows this Courts

holding inHeiligmann. She thenmisconstrues recent property rights cases from this Court

and distorts the court of appeals Medlen opinion until it is virtually unrecognizable.

Specifically, Strickland contends that the court of appeals ignored the Heiligmann case,

and in doing so, created a new cause of action that permits dog owners to recover for the

loss of their pets comparable to what they would be entitled to recover for the loss of a

spouse, parent, or child. [Brief @ xv] Strickland also argues that the courts decision

impermissibly allowed mental anguish damages for negligent damage to personal

property.

Stricklands reliance on out-of-context quotes fromBrownandLikesto support her

arguments is so misplaced as to border on disingenuous. In Brown, the relevant issue

before this Court was the lack of evidentiary support for the trial court's award of damages

for the loss of certain personal property. 369 S.W.2d at 304-05. The Court recited that

the most fundamental rule of damages that every wrongful injury or loss to persons or

property should be adequately and reasonably compensated requires the allowance of

damages in compensation for the reasonable special value of such items to their owner


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taking into consideration the feelings of the owner for such property.Id.at 305 (emphasis

added). This Court then reversed the award of special damages because there was no

evidentiary support for those damages. Nothing in Brown supports Stricklands overly

broad interpretation of it.

Strickland similarly misstates the effect of this Court's opinion in Likes. 962

S.W.2d 469. The question before this Court inLikeswas the propriety of mental anguish

damages for personal property destroyed when the Likes house flooded. See id.at 497-

99. Because mental anguish damages are not an issue in this case, Strickland's reliance

on bits and pieces of specific language in Likes is neither relevant nor persuasive.

Stricklands interpretation of the appellate courts decision in Medlen misses the

mark as well. The Medlens did not seek mental anguish damages. They sought recovery

for the wrongful destruction of their personal propertynothing more, nothing less. The

court of appeals addressed only the issue before it. Thus, its decision is limited to dogs,

which have long been recognized as personal property in Texas, and in particular, the

Medlens dog.

Strickland also argues that special damages are available only where the item in

question is irreplaceable. She posits that, in as much as there is a virtually endless supply

of dogs, a new one is always readily available, thus, special damages for dogs are always

improper. In so doing, Strickland underscores the fallacy of her position. If the property

destroyed can be replaced by a similar (but not identical) item, why not simply award


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replacement costs for a great-grandmothers antique wedding veil or an ancestors

heirloom photo? A trip to the local antique mall would surely yield a suitable

replacement. Of course, the new veil would not have the identical characteristics of the

lost family treasure and the face staring out of the very old photograph would be a

stranger, but surely these replacement heirlooms would be almost as good as the

originals. But the law does not require that such substitutions be made for the sake of

judicial economy and no such result is proper in this case.

Here, the Medlens sought redress by suing Strickland, the responsible party. In

doing so, the Medlens were then, and still are, simply seeking access to the courts.

Strickland, however, appears to presuppose that if a jury is empanelled in this case,

floodgates will open, reason and common sense will flee the courtroom, and million dollar

verdicts will be awarded in lawsuits for the loss of pet gerbils and goldfish. But the

Medlencourts decision is nowhere near as expansive as Strickland would lead this Court

to believe. The court of appeals opinion did not grantthe Medlens request for intrinsic

damages for the loss of their dog; it simply allows them to seek those damages. The dollar

amount the Medlens are entitled to recover, if any, lies in the sound discretion of a jury.

See Garey Constr. Co., Inc. v. Thompson, 697 S.W.2d 865, 867 (Tex. App.Austin 1985,

no pet.) (dollar value for intrinsic loss must be left to the jury); Lucas v. Morrison, 286

S.W.2d 190 (Tex. Civ. App. 1956, no writ) (same). And like other property cases, the jury

cannot assess damages where there is no evidence to support them. Dunnagan v. Watson,


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204 S.W.3d 30 (Tex. App.Fort Worth 2006, pet. denied). Stricklands lack of confidence

in the jury system is unfounded and provides no legitimate basis to deny the Medlens their

day in court.

Because Texas law permits owners to seek damages for the destruction of their

personal property, the court of appeals did not err in reversing the trial courts order of

dismissal. The Medlens thus respectfully request that this Court deny Stricklands petition

to create a judicial exception to existing state law.

Issue Three:

Did Section 101.106(f) of the Texas Civil Practice and Remedies Code bar the

court of appeals from deciding the merits of the Medlens appeal?

Strickland argues that Section 101.106(f) as construed by this Court in Franka v.

Velasquez, 332 S.W.3d 367 (Tex. 2011), requires a trial court to sua spontedismiss a case

brought against a state employee in her individual capacity. In doing so, Strickland seeks

to impose an affirmative duty on the trial court even though the employee has not filed a

motion to dismiss. But Strickland takes this argument further. She would also impose a

corollary duty on the appellate courts. She would likewise divest the appellate court of

jurisdiction in cases where the trial court could have disposed of the case by filing a

motion on behalf of the state employee. Stricklands line of reasoning suggests a judicial


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activism that is contrary to the letter and the spirit of the substantive and procedural laws

of this State.

In this case, Strickland filed special exceptions in the trial court but did not file a

motion to dismiss under Section 101.106(f). Such a motion is statutorily required before

the trial court can dismiss a suit against a government employee under Section 101.106(f).

See generally Antonio v. Bailey, 332 S.W.3d 395, 401 (Tex. 2011) (dismissal under

Section 101.106(f) is not automatic; government employee must file a motion before he or

she may be dismissed); see also Franka, 332 S.W.3d at 380 (Section 101.106(f) leaves

timing of motion to dismiss to the employee);University of Texas Sw. Med. Ctr. v. Estate

of Arancibia, 324 S.W.3d 544, 551 (Tex. 2011) (Section 101.106(f) lists several

prerequisites that must be satisfied before an employee is entitled to dismissal.);Mission

Consol. Indep. School Dist. v. Garcia, 253 S.W.3d 653, 659 (Tex. 2008) (employee

should seek his own dismissal under subsection (f)). Nothing in this Courts decision in

Franka, or any prior or subsequent decisions of this Court, divests the court of appeals of

jurisdiction in cases where a state employee could have, but did not, file a proper motion

to dismiss.

PRAYER

For all the reasons stated above, the Medlens respectfully request that this Court

deny Stricklands petition for review. In the alternative, the Medlens pray that this Court

affirm the court of appeals decision allowing them to seek damages for the wrongful


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destruction of their property, and deny Stricklands request to carve out an exception to

that established right.

By: /s/ Randall E. Turner By: /s/ Sondrea J. KingRANDALL E. TURNER SONDREA J. KINGSBN: 20328310 SBN: 24003728BAILEY & GALYEN SUSAN BLEIL1901 Airport Freeway SBN: 14056720Bedford, Texas 76021 LAW OFFICE OF BLEIL & KINGTel: 817-359-7065 5012 Birch Hollow LaneFax: 817-764-6336 Fort Worth, Texas 76132Email:[email protected] Telephone: 817.680.0228

COUNSEL FOR RESPONDENTS
mailto:[email protected]:[email protected]:[email protected]:[email protected]

8 medlen brief resp

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