William Price, Sr. and Haitham Baqdounces v. Luis Sanchez, 14-15-00508-CV

On March 18, 2014 League City police arrested Luis Sanchez and Action Towing, Inc. (Action) towed his vehicle; Action sent notice and the police later deemed the vehicle abandoned and arranged an auction.
Texas Auto Title/League City conducted a public auction on May 29, 2014; Dynamo Auto Sales (Dynamo) purchased the vehicle according to the auction receipt.
Sanchez twice attempted to recover the truck; Action told him it was on hold and later that it was not there. Sanchez’s counsel demanded return in June; Action then asserted storage fees and ultimately sought a purchase price around $4,000.
Sanchez sued Price and Baqdounes individually for conversion (Price is owner of Action; Baqdounes part-owner of Action and owner of Dynamo). Trial court entered judgment for Sanchez ordering return of the vehicle and $2,500 in attorney’s fees.
On appeal, defendants argued evidence was legally insufficient to hold them personally liable because documentary and testimonial evidence showed the towing, storage, and auction were conducted by Action and the law enforcement agency, not the individual defendants.
The court of appeals reversed and rendered: it held Sanchez failed to prove Price or Baqdounes individually exercised unlawful dominion or refused his demand, and therefore Sanchez took nothing; the attorney-fee award was reversed as well.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legal sufficiency of evidence that defendants were individually liable for conversion	Sanchez argued defendants did not plead lack of individual liability and trial judge found in his favor	Defendants argued the evidence showed Action (a corporation) and the police handled towing/auction; no evidence either defendant personally controlled, refused return, or participated	Reversed: evidence legally insufficient to establish individual conversion liability because no proof defendants personally exercised wrongful dominion or refused demand
Award of attorney’s fees	Sanchez obtained trial-court fee award and argued entitlement	Defendants argued fee award depends on prevailing party/status and statutory basis	Reversed: fee award vacated because Sanchez did not prevail on any claim and sought no statutory basis allowing recovery as non-prevailing party

Light v. Wilson, 663 S.W.2d 813 (Tex. 1983) (failure to file verified denial of individual capacity does not bar challenging sufficiency of evidence of individual liability)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (legal-sufficiency standard and view of evidence in the light most favorable to verdict)
Waisath v. Lack's Stores, 474 S.W.2d 444 (Tex. 1971) (definition of conversion)
Freezia v. IS Storage Venture, LLC, 474 S.W.3d 379 (Tex. App.—Houston [14th Dist.] 2015) (elements of conversion)
Action Towing, Inc. v. Mint Leasing, Inc., 451 S.W.3d 525 (Tex. App.—Houston [1st Dist.] 2014) (plaintiff bears burden to prove individual conversion liability)