Lane-Valente Industries (Nat'l), Inc v. J.P. Morgan Chase, N.A. and Bovis Lend Lease, Inc., 468 S.W.3d 200

Lane-Valente contracted to provide renovation services for projects for Lend Lease on Chase-owned bank facilities; Lane-Valente failed to pay Texas sales taxes and Lend Lease paid the Comptroller $186,480.73 and sued Lane‑Valente. Lane‑Valente impleaded Chase.
Parties mediated and signed a Rule 11 settlement providing the parties would execute “full mutual releases in favor of each other, including an agreement that this settles and resolves all claims/issues ... that were raised or that could have been raised/brought out of the incident(s) made the basis of this suit.”
The parties could not agree on release language; the trial court replaced the agreed language with narrower wording limiting released claims to those raised or that could have been raised out of the incident made the basis of the suit.
Lane‑Valente sued to enforce the Rule 11 agreement (breach of contract and declaratory judgment); both sides moved for summary judgment. The trial court granted appellees’ motion, ordered execution of the narrower release, dismissed the original suit with prejudice, and awarded fees.
On appeal, the Fourteenth Court reviewed whether the Rule 11 agreement was ambiguous and whether summary judgment for either side was proper; it also considered appellees’ request for sanctions for a frivolous appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of the Rule 11 release — whether it requires broad mutual releases of all claims or only claims "raised or that could have been raised" from the incident	Lane‑Valente: the agreement’s phrase “full mutual releases” plus the word "including" shows the parties intended broader mutual releases beyond merely claims arising from the incident	Appellees: parties intended to release only claims raised or that could have been raised out of the incident (i.e., the original suit’s claims)	The agreement is ambiguous because it reasonably supports both interpretations; issue is for further proceedings, not resolved by summary judgment
Entitlement to summary judgment	Lane‑Valente: it was entitled to enforcement of the Rule 11 terms as written	Appellees: they were entitled to summary judgment enforcing the narrower release the trial court ordered	Trial court properly denied Lane‑Valente’s motion; trial court erred in granting appellees’ cross-motion — summary judgment inappropriate given contract ambiguity
Request for appellate sanctions under Tex. R. App. P. 45	Appellees: appeal was frivolous and just damages should be awarded	Lane‑Valente: appeal had reasonable grounds and authority to support reversal	Appeal not objectively frivolous; sanctions denied

Exxon Corp. v. Emerald Oil & Gas Co., 331 S.W.3d 419 (Tex. 2010) (standard of review for summary judgment)
Coker v. Coker, 650 S.W.2d 391 (Tex. 1983) (summary judgment inappropriate when contract ambiguous)
Padilla v. LaFrance, 907 S.W.2d 454 (Tex. 1995) (effect of party withdrawing consent to settlement before judgment)
Mantas v. Fifth Court of Appeals, 925 S.W.2d 656 (Tex. 1996) (settlement enforcement as contract when consent withdrawn)
J.M. Davison, Inc. v. Webster, 128 S.W.3d 223 (Tex. 2003) (contract construction principles; give effect to parties’ intent)
National Union Fire Ins. Co. v. CBI Indus., 907 S.W.2d 517 (Tex. 1995) (contract ambiguity analysis)
Glassman v. Goodfriend, 347 S.W.3d 772 (Tex. App.—Houston [14th Dist.] 2011) (standards for awarding appellate sanctions under Rule 45)