Anne Coyle // Stephen Casey v. Chad Walker and Alisha Flood // Cross-Appellee, Anne Coyle
03-23-00599-CV
Tex. App.Jan 24, 2025Background
- Anne Coyle, Chad Walker (her brother), and Alisha Flood (Walker’s ex-wife) entered into a mediated settlement agreement (MSA) in 2015 to resolve two lawsuits, agreeing to pay Coyle $2,000 jointly and severally.
- The MSA terms were incorporated into final orders in two separate cases, with monthly payments of $27.70 from each defendant over 36 months.
- Coyle received certified checks from Walker ($1,055.50) and Flood ($1,000), but disputed satisfaction of the debt, notably claiming she could not cash Flood’s check.
- In 2017, Walker and Flood filed the present suit for declaratory judgment that the judgments and obligations had been satisfied. Coyle counterclaimed and further challenged their claims, seeking attorney’s fees.
- The trial court ruled for Walker and Flood, found the $2,000 obligation was satisfied, and awarded attorney’s fees against Coyle. The court also sanctioned Stephen Casey, former counsel for Walker and Flood, for material misrepresentations in a vexatious litigant motion.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Jurisdiction (Declaratory Judgment) | Coyle: No justiciable controversy; trial court cannot interpret prior judgments | Walker & Flood: Actual dispute about satisfaction of obligations post-judgment | Court had jurisdiction; resolved controversy about satisfaction, not impermissible interpretation |
| Res Judicata / Collateral Estoppel | Coyle: Prior final orders bar the relief sought | Walker & Flood: Suit is about performance under MSA after judgment, not relitigation | Not barred; suit involved post-judgment conduct, not subject matter of prior orders |
| Attorney’s Fees | Coyle: If final judgment reversed, fee award should also be reversed | Walker & Flood: Affirmation of judgment sustains fee award | Affirmed; fee award stands as judgment affirmed |
| Application of Flood’s Check | Coyle: Flood’s altered cashier’s check was not valid tender; obligation not satisfied | Flood: Certified check delivered; obligation discharged even if uncashed and unreturned | Valid tender; Coyle’s non-return meant check applied toward obligation |
| Sufficiency of Evidence (Satisfaction) | Coyle: Insufficient evidence that obligations satisfied; sought post-judgment interest | Walker & Flood: Evidence showed receipt of payments totaling $2,000; MSA didn’t provide for interest | Sufficient evidence; $2,000 satisfied, no post-judgment interest due under MSA |
| Sanctions Against Casey | Casey: Presumption of good faith not overcome; court misapplied legal standards | Coyle: Material misrepresentations made, failed to disclose contrary authority | Sanctions upheld; Casey’s actions warranted under Rule 13/Chapter 10 |
Key Cases Cited
- Frost Nat’l Bank v. Fernandez, 315 S.W.3d 494 (Tex. 2010) (subject-matter jurisdiction is a question of law)
- Bonham State Bank v. Beadle, 907 S.W.2d 465 (Tex. 1995) (justiciable controversy for declaratory judgments)
- Amstadt v. U.S. Brass Corp., 919 S.W.2d 644 (Tex. 1996) (res judicata—when subsequent actions are barred)
- Kachina Pipeline Co. v. Lillis, 471 S.W.3d 445 (Tex. 2015) (trial court discretion on attorney’s fee awards under UDJA)
- Guaranty Fed. Sav. Bank v. Horseshoe Operating Co., 793 S.W.2d 652 (Tex. 1990) (effect of certified checks on debt discharge)
- City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standard for legal sufficiency review)