Prestige Ford Garland Ltd. Partnership v. Morales
336 S.W.3d 833
Tex. App.2011Background
- Morales signed an August 1999 lease with Prestige Ford to purchase a 1999 Ford Expedition and began making monthly payments.
- Morales later learned in July 2004 that the transaction was financed as a lease, not a purchase, and she could not complete ownership.
- Prestige Ford presented a November 1999 sales contract showing Morales as buyer, but the parties’ actual structure remained a lease financed by World Omni.
- World Omni notified Morales in 1999 that it had purchased her lease contract; Morales’ lease statements identified her as lessee, not owner.
- Morales sued in May 2006 for fraud, DTPA, and promissory estoppel; trial court denied JNOV on promissory estoppel, and the jury awarded damages.
- The appellate court held that Prestige Ford breached its promise to sell by having Morales sign a lease in August 1999, making the promissory estoppel claim time-barred under a four-year statute of limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| accrual date for promissory estoppel | Morales: accrues in 2004 when ownership was denied. | Prestige Ford: accrues in August 1999 when the lease was signed. | Accrual in August 1999; promissory estoppel time-barred. |
Key Cases Cited
- Wheeler v. White, 398 S.W.2d 93 (Tex. 1965) (promissory estoppel accrual hinges on breach)
- Murphy v. Campbell, 964 S.W.2d 265 (Tex. 1997) (limitations apply to discovery rule for damages)
- Johnson & Higgins of Tex., Inc. v. Kenneco Energy, Inc., 962 S.W.2d 507 (Tex. 1998) (accrual and limitations analysis for mixed actions)
- Moreno v. Sterling Drug, Inc., 787 S.W.2d 348 (Tex. 1990) (general accrual principles for legal injuries)
- Provident Life & Accident Ins. Co. v. Knott, 128 S.W.3d 211 (Tex. 2003) (statutory accrual timing in liability actions)