Anthony Leo Sheridan and CCS Asset Management, Inc. v. Kelli D. Williams, Michael Richardson, and Scoutview Sports, 13-21-00342-CV

Williams owned a long‑held residential Property and agreed with Richardson and ScoutsView to use it as collateral to secure funding for Williams to invest in ScoutsView.
CCS Asset Management, Inc. (CCS) and its VP Sheridan executed a Corporate Partnership Agreement with ScoutsView; Williams was listed as a partner/member but did not sign. The Agreement contemplated using the Property as collateral, a second investment by CCS, formation of an Advisory/Advisory Partnership with management authority, and stated CCS "shall allow [ScoutsView] to purchase [the Property] from CCS at any time."
In August 2017, CCS and Sheridan sold the Property without notifying Williams, Richardson, or ScoutsView. Plaintiffs sued for common law fraud, statutory fraud, breach of contract, and sought to hold Sheridan individually liable under an alter‑ego/veil‑piercing theory.
Plaintiffs moved for partial summary judgment on breach of contract and statutory fraud. The trial court sustained defendants’ evidentiary objections, granted summary judgment for plaintiffs, and later fixed damages; defendants appealed.
On appeal, defendants challenged finality, sufficiency of evidence for statutory fraud, whether the advisory partnership was a necessary party, and whether Sheridan could be individually liable (alter ego).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Finality / Jurisdiction	June 22, 2021 order disposes of all issues and is appealable	Final order is not final because counterclaims remained unresolved	Affirmed jurisdiction: order contains clear and unequivocal language disposing of case; appeal allowed
Statutory fraud (intent)	Sheridan/CCS promised to follow the Partnership Agreement but secretly sold the Property and failed to fund ScoutsView, so fraud as a matter of law	No evidence of intent to defraud when promise made; at most a changed mind or partial performance	Reversed: intent is a fact question; plaintiffs did not prove absence of intent to perform as a matter of law; remanded
Breach of contract — missing Advisory Partnership as necessary party	(Implied) judgment valid without naming Advisory Partnership	Advisory Partnership was a necessary party and omission invalidates summary judgment	Overruled: defendants failed to preserve by verified pleading; summary judgment on breach against CCS affirmed
Sheridan's individual liability (alter ego / personal benefit)	Sheridan’s conduct (fraudulent sale) justifies piercing corporate veil to hold him personally liable	Sheridan acted for CCS; no evidence of alter ego, commingling, or that Sheridan acted for direct personal benefit	Reversed as to Sheridan: plaintiffs failed to establish alter ego or that Sheridan perpetrated fraud primarily for his direct personal benefit; remanded

Tex. A & M Univ. Sys. v. Koseoglu, 233 S.W.3d 835 (Tex. 2007) (interlocutory vs final judgment principles)
Bella Palma, LLC v. Young, 601 S.W.3d 799 (Tex. 2020) (finality language can make an order final even if defective)
In re Guardianship of Jones, 629 S.W.3d 921 (Tex. 2021) (no magic words required for finality; look to clear and unequivocal intent)
Formosa Plastics Corp. USA v. Presidio Eng’rs and Contractors, 960 S.W.2d 41 (Tex. 1998) (promise made with no intent to perform can support a fraud claim)
Spoljaric v. Percival Tours, Inc., 708 S.W.2d 432 (Tex. 1986) (intent is a fact question for the trier of fact)
Lujan v. Navistar, Inc., 555 S.W.3d 79 (Tex. 2018) (summary judgment reviewed de novo; burdens for movant/nonmovant)