Buddy Casteel and Jaret Brandon Casteel v. Amelia Stayton
04-15-00273-CV
| Tex. App. | Oct 12, 2015Background
- Appellants (Buddy and Jaret Casteel) operated a commercial business on property owned by appellee Amelia Stayton and were subject to a notice to vacate dated August 11, 2014.
- In early September 2014 Jaret Casteel contacted Stayton about buying the property, extending possession past a September 15 deadline, and negotiating a new month-to-month lease at higher rent; Stayton denied those requests and told him the property was under contract for sale.
- On September 14, 2014 the Casteels produced a handwritten ten‑year lease signed by Melissa Baugh purporting to bind Stayton’s property; the document lacked customary commercial-lease terms and no evidence was offered that Baugh had authority.
- Trial court granted eviction and possession to Stayton; Casteels appealed, arguing estoppel/apparent authority based on Baugh’s signature and prior dealings with her.
- Appellee argued (and trial court found) that only Stayton’s conduct at the relevant time matters, that the Casteels had notice of limits on Baugh’s authority, and that the Casteels’ evidence and credibility were insufficient to prove apparent authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stayton can be bound by a purported 10‑year lease signed by Baugh under apparent authority/estoppel | Casteels: prior dealings with Baugh and the signed document estop Stayton from denying the lease | Stayton: only the principal’s conduct at the relevant time matters; Casteels dealt directly with Stayton and were denied, had notice of sale/limitations on authority | Court affirmed: evidence insufficient to show a reasonably prudent person would believe Baugh had authority to bind Stayton |
| Whether Casteels had notice of limitations on agent’s power that preclude apparent authority | Casteels: historical dealings with Baugh created lingering apparent authority | Stayton: Casteels directly communicated with owner and were told there would be no new lease and that the property was selling | Held: Casteels had notice of limitations; apparent authority unavailable |
| Whether the handwritten agreement’s form and lack of supporting proof undermines enforcement | Casteels: document reflects parties’ intent to lease long term | Stayton: document lacked typical commercial-lease provisions, no proof Baugh signed or had authority, no prior long-term lease with owner | Held: Form and lack of corroborating evidence supports rejection of enforcement against Stayton |
| Whether factfinder reasonably disbelieved Casteels’ testimony | Casteels: testimony that they believed Baugh owned/controlled property | Stayton: actions (contacting owner, offers to buy/lease) contradicted that belief; trial court best judge of credibility | Held: Trial court’s credibility findings sustained; testimony not credible |
Key Cases Cited
- Gaines v. Kelly, 235 S.W.3d 179 (Tex. 2007) (apparent authority assessed by principal’s conduct and reasonably prudent person standard)
- City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (appellate review limits; trial court is sole judge of witness credibility)
- Cain v. Bain, 709 S.W.2d 175 (Tex. 1986) (standard for reviewing factual sufficiency when appellant bore burden)
- Douglas v. Panama, 504 S.W.2d 776 (Tex. 1974) (apparent authority unavailable where party had notice of agent’s limitations)
- Chastain v. Cooper & Reed, 257 S.W.2d 422 (Tex. 1953) (reasonable diligence/discretion standard in assessing agent authority)