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Baker Marine Corp. v. Moseley

Citations: 645 S.W.2d 486; 1982 Tex. App. LEXIS 5187Docket: 1982cv

Court: Court of Appeals of Texas; September 9, 1982; Texas; State Appellate Court

Narrative Opinion Summary

In this appellate case, the Texas Court of Appeals reviewed a jury verdict in favor of an employee, Moseley, under an employment agreement following the acquisition of his company by Baker Marine Corporation. The agreement outlined a compensation structure that included a base salary and additional earnings linked to project cost efficiency. Moseley claimed he was owed additional compensation beyond his salary for several projects. The jury ruled in favor of Moseley, awarding $125,000 based on unpaid amounts for specific jobs. Baker Marine contested the jury charge's formulation under Rule 277, alleging it failed to address the terms of employment adequately and commented improperly on evidence weight. However, the court upheld the trial court's discretion, finding no abuse and affirming the decision. Additionally, the court addressed the sufficiency of evidence, particularly for partially completed jobs that received full damage awards, suggesting a remittitur to correct the award proportionally to project completion. Upon Moseley's acceptance of the remittitur, the judgment was reformed to $111,000, affirming the trial court's earlier judgment.

Legal Issues Addressed

Employment Agreement and Compensation Structure

Application: The case examines the interpretation and application of a compensation structure in an employment agreement following the acquisition of a company.

Reasoning: The agreement stipulated that Moseley would manage the renamed Baker Manufacturing, producing gear boxes for offshore rigs, with a compensation structure that included a guaranteed salary and a formula for additional earnings based on the project's cost relative to $150,000.

Jury Verdict and Evidence Sufficiency

Application: The court addressed the sufficiency of evidence supporting the jury's verdict, particularly concerning incomplete projects that received full damage awards.

Reasoning: Appellant argues that the evidence was insufficient to justify the jury's verdict regarding jobs 07 and M15, both of which were only 65% completed, yet received the same damage award as fully completed jobs.

Remittitur in Damage Awards

Application: The court ordered a remittitur when the damage award was excessive due to incomplete project status, adjusting the award to reflect the completion percentage.

Reasoning: The trial court's judgment was affirmed, contingent upon the appellee filing a remittitur of $14,000.

Special Issue Submission under Texas Rule 277

Application: The court assessed the trial court's discretion in submitting special issues to the jury under Rule 277, confirming that the issues were fairly presented without assuming disputed facts.

Reasoning: Under Rule 277, Texas courts allow broad discretion in submitting special issues, provided they fairly present disputed issues to the jury.