Crawford v. Pullman, Inc – Case Brief Summary (Texas)

Crawford v. Pullman, Inc., 630 S.W.2d 377, 379-80 (Tex. App.--Houston 14th Dist. 1982, no writ), involved unprovided portions of a written contract in a non-insurance context.

In Crawford, the trial court granted a traditional motion for summary judgment in favor of a plaintiff suing on two lease agreements. See id.

Though it was clear from the front pages of the lease agreements that there were terms on the reverse sides, the plaintiff provided the trial court with only the front sides. See id.

Although the appellant did not complain about the appellee's failure to provide all of the terms of the agreements, this court held that the trial court erred in granting summary judgment without reviewing all the provisions of the written contracts. See id.

Noting that the missing provisions (on the unprovided reverse sides) could be relevant to whether the appellee was entitled to judgment as a matter of law, this court held that a summary-judgment movant was not entitled to relief based on the two contracts because it did not prove all of the provisions of those contracts. See id.

In Crawford, the Court held that a party could not obtain relief by means of a traditional motion for summary judgment if that relief is based on a contract and the record does not contain proof of all of the contract's terms. See Crawford, 630 S.W.2d at 379-80.