Capstone Healthcare Equipment Services, Inc. ex rel. Health System Group, L.L.C. v. Quality Home Health Care, Inc.

Summary

The Texas Court of Appeals affirmed summary judgments for Quality Home Health Care, Inc. and Donna Vansickle in a dispute arising from a stock purchase agreement. The court held that Capstone’s breach-of-contract claim was barred by the four-year statute of limitations because Capstone knew of the alleged breaches more than four years before filing suit. The court also held that Capstone waived challenges to summary judgment on its fraud, quasi-contract, unjust enrichment, and wrongful foreclosure claims through inadequate briefing.

Holdings

1. Capstone waived any complaint concerning those claims because its brief offered no argument, authority, or analysis showing error in the trial court's rulings on them.
2. The trial court properly granted summary judgment because Capstone knew of the alleged contractual breaches by April 2001 and filed suit more than four years later.
3. The continuing-contract doctrine did not delay accrual of Capstone's breach-of-contract claim until April 2002.

Questions Presented

1. Whether the trial court properly granted summary judgment on Capstone's breach-of-contract claim based on the statute of limitations.
2. Whether the continuing-contract doctrine delayed accrual of Capstone's breach-of-contract claim until Vansickle sold the stock in April 2002.
3. Whether Capstone waived appellate complaints concerning the fraud, quasi-contract, unjust enrichment, and wrongful foreclosure claims by failing to adequately brief them.

Disposition

affirmed