TX STATETexas Court of Appeals, 2nd District (Fort Worth)
2011

Ralph P. Larrison, Jr. v. Catalina Design

Texas Court of Appeals, 2nd District (Fort Worth) • Decided 2011Modified

HOLDING

A general contractor (Larrison) sold his company while owing a masonry subcontractor (Catalina) final payment on three projects. The court found Larrison misapplied construction trust funds by keeping money that should have gone to pay Catalina's outstanding invoices. The trial court's judgment was upheld, but the court removed attorney's fees that weren't supported by statute. This case shows that general contractors can't hold onto trust funds owed to subs, even when selling the company.

KEY FINDINGS

Lien Waiver

Trust funds held for subcontractors must be paid before the GC can use or retain that money for other purposes—no exceptions for disputes or company sales

Lien Rights

If you're owed money when a GC sells their company, the sale doesn't erase the debt; you can pursue the original owner personally under Texas Property Code § 162.031

FULL COURT OPINION