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Keywords

lawsuitplaintiffdefendantdamagesliabilityrespondentexemplary damages
defendantdamagesliabilitytrialcorporationpunitive damagesrespondentexemplary damages

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Purvis v. Prattco, Inc., 595 S.W.2d 103

Facts

The Purvis family, registered guests at the Holiday Inn, experienced an incident on the night of July 5 when they were awakened by a phone call from the night manager, Amin Baji, who questioned their presence in the room. After a series of confrontations, including the involvement of a security guard and police, the Purvis family was told they had to leave the motel despite being registered guests. The incident disrupted their vacation plans and led to a lawsuit for damages.

Petitioners, Forrest H. Purvis and wife, individually and as next friend of their minor daughters, brought this suit to recover actual and exemplary damages from respondent, Prattco, Inc., d/b/a Holiday Inn D-FW Airport North. Petitioners alleged that their private use, as registered guests, of a motel room was interfered with in the middle of the night by respondent's employee, Amin Baji.

Issue

Whether the evidence conclusively establishes that Baji was acting in a managerial capacity at the time of the incident, thereby subjecting the corporate defendant to liability for exemplary damages.

The sole question before us is whether the evidence conclusively establishes that Baji was acting in a managerial capacity at the time of the incident in question so as to subject the corporate defendant to liability for exemplary damages.

Rule

In Texas, a principal is liable for exemplary damages due to the acts of an agent if the agent was employed in a managerial capacity and was acting within the scope of employment.

The rule in Texas, as restated by this Court in Fisher v. Carrousel Motor Hotel, Inc., 424 S.W.2d 627 (Tex.1967), is that a principal or master is liable for exemplary or punitive damages because of the acts of his agent, but only if: (a) the principal authorized the doing and the manner of the act, or (b) the agent was unfit and the principal was reckless in employing him, or (c) the agent was employed in a managerial capacity and was acting in the scope of employment, or (d) the employer or a manager of the employer ratified or approved the act.

Analysis

The court found that Baji, identified as the night manager, had responsibilities that included overseeing the motel's operations during his shift. Despite the respondent's claim that Baji's role was merely that of a night auditor, the evidence showed that he was the senior employee present and had the authority to manage the motel's affairs during the night shift. Thus, the court concluded that Baji was acting in a managerial capacity when he interfered with the Purvis family's use of their room.

This evidence demonstrates conclusively that Baji's authority matched his designated title of 'night manager.' The term 'manager,' as applied to a representative of a corporation, implies that the management of the affairs of the company has been committed to him with respect to the enterprise under his charge. Here, Baji was in charge of, and responsible for, the operation of this large motel near a major airport between the hours of 11:00 p.m. and 7:00 a.m. As such he was employed by respondent in a managerial capacity.

Conclusion

The Supreme Court reversed the lower courts' judgments and remanded the case with instructions to include the recovery of exemplary damages for the plaintiffs.

Accordingly, we reverse the judgments of the courts below and remand the cause to the trial court with instructions that the judgment be reformed to include petitioners' recovery of exemplary damages.

Who won?

The Purvis family prevailed in the case because the court determined that the employee's actions warranted exemplary damages due to his managerial role.

Petitioners concede that since no jury issue was submitted or requested by them as to Baji's authority, the judgments of the courts below are correct unless the evidence establishes as a matter of law that Baji was acting in a managerial capacity on the occasion in question.

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