Weaver v. Texas Capital Bank N.A., 2011 U.S. App. LEXIS 20964

Weaver, a member of SL Management, signed guaranties for four Texas Capital loans totaling $978,719 secured by land in Tarrant County.
SL Management filed Chapter 11 bankruptcy; Texas Capital filed an unobjected proof of claim and was classified as Class 10 creditor in the plan.
The plan provided that collateral would be sold to satisfy Class 10, or, if not, surrendered to Texas Capital to fully satisfy Class 10, with deficiencies treated as Class 12 claims.
Section 10.3 of the plan allegedly enjoined collection against guarantors while the plan remained not in default; Weaver argued this provision foreclosed Texas Capital’s state-court default judgment against him.
On plan confirmation, no sale of collateral occurred; the properties were surrendered on the Effective Date, and Texas Capital foreclosed later, yielding a deficiency of $431,659.34.
Texas Capital obtained a state-court default judgment against Weaver; Weaver then filed this federal action seeking declaratory relief that the guaranties were satisfied by the plan and collateral surrender.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Rooker-Feldman deprive the court of jurisdiction?	Weaver argued preclusion or voidness issues affect jurisdiction.	Texas Capital urged Rooker-Feldman to bar review of the Texas judgment.	Rooker-Feldman does not deprive jurisdiction.
Whether the case is barred by res judicata.	Weaver claims the suit seeks declaratory relief not barred by prior judgment.	Weaver's claim is a defense to payment that should have been raised earlier.	Weaver's claim is barred by res judicata under Texas law.
Whether Texas state default judgment has preclusive effect.	State judgment should be void or not given preclusion due to stay violations.	Default judgment has preclusion effect and bars later claims arising from the same transaction.	Default judgment has preclusive effect under Texas law on the related claim.
Whether the bankruptcy plan enjoined collection against guarantors.	Plan language enjoined claims against guarantors absent a default.	Plan provisions govern plan satisfaction; not voiding state judgments.	Res judicata controls; plan does not sustain Weaver's declaratory relief; judgment for Texas Capital.
Do the preclusion and plan interactions defeat Weaver's claim for declaratory relief?	Declaratory relief should reflect plan satisfaction of the guaranties.	Claims should have been raised in the prior action and are barred.	Res judicata bars the declaratory relief.

Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (independent claim doctrine; preclusion governs related judgments)
Igal v. Brightstar Info. Tech. Grp., Inc., 250 S.W.3d 78 (Tex. 2008) (res judicata; compulsory counterclaims; transactional approach)
Ingersoll-Rand Co. v. Valero Energy Corp., 997 S.W.2d 203 (Tex. 1999) (compulsory counterclaims; same transaction standard)
Barr v. Resolution Trust Corp., 837 S.W.2d 627 (Tex. 1992) (res judicata; transaction-related claims)
Moyer v. Mathas, 458 F.2d 431 (5th Cir. 1972) (default judgments preclusive absent fraud or lack of jurisdiction)
Houtex Ready Mix Concrete & Materials v. Eagle Constr. & Envtl. Servs., L.P., 226 S.W.3d 514 (Tex.App.—Houston [1st Dist.] 2006) (default judgments and preclusion under Texas law)
Reimer v. Smith, 663 F.2d 1316 (5th Cir. 1981) (last-in-time rule; estoppel in Texas)
South Plains Switching, Ltd. Co. v. BNSF Ry., 255 S.W.3d 690 (Tex. App.—Amarillo 2008) (claims arising from same contract; transactional approach)
Suntex Dairy v. Bergland, 591 F.2d 1063 (5th Cir. 1979) (injunctions are not void ab initio when violated)
Reliant Energy Servs., Inc. v. Enron Can. Corp., 349 F.3d 816 (5th Cir. 2003) (stay and third-party protections; limits of automatic stay)