In Crawford v. Ancira, No. 04-96-00078-CV, 1997 WL 214835 (Tex. App.--San Antonio, April 30, 1997, no writ), a limited partner plaintiff brought fraud claims against another limited partner in an attempt to avoid certain contractual obligations, claiming that limited partner had made misrepresentations to her that were contrary to the contractual terms. Recognizing that the plaintiff's fraud claim was only viable if a fiduciary or confidential relationship existed between the parties, the San Antonio Court of Appeals rejected her claim. Id. The court reasoned that limited partners do not have the broad managerial powers enjoyed by general partners and, thus, "a person's mere status as a limited partner is insufficient to create fiduciary duties."