Trenholm v. Ratcliff

George Trenholm, Jr. (plaintiff) and Robert Trenholm owned a business that built custom homes. The Trenholms and other similar business owners attended a presentation by Raymond Ratcliff, Jr. (defendant), a land developer and owner of an investment corporation. At the meeting, Ratcliff solicited the attendees to purchase lots in a new subdivision called Greenhollow. Ratcliff told the Trenholms and others that: (1) a mobile-home park located near Greenhollow would be a future shopping center, (2) the mobile-home park had already been sold, (3) its tenants would be instructed to move, and (4) the land would be bulldozed in the coming months. The Trenholms purchased 18 lots in Greenhollow. However, Ratcliff’s statements concerning the mobile-home park were false; the property had not been sold for the purpose of building a shopping center. The Greenhollow subdivision failed financially, and homes in Greenhollow were sold at a loss. Robert Trenholm sold his interest in the company to George Trenholm. Afterward, George Trenholm sued Ratcliff and others for fraud. After a trial, the jury found that Ratcliff had made false representations to Trenholm with the intent to induce Trenholm and others to purchase Greenhollow lots. Additionally, the jury concluded that Ratcliff made the statements recklessly, with malice, and that Trenholm relied on the false statements in purchasing the 18 lots. The jury awarded Trenholm nearly $144,000 in compensatory damages and over $250,000 in exemplary damages. Trenholm and Ratcliff each moved for a directed verdict. Ratcliff alternatively moved for a judgment notwithstanding the verdict. The trial court held for Ratcliff. Trenholm appealed. The court of appeals affirmed the judgment of the trial court. The Supreme Court of Texas granted certiorari.