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Research Assessment #10 -A Basic Review of Michael Beal v. Pruvit Ventures, Inc.

One of the possible avenues for my final product I am planning on bringing up this Friday during my interview with Mr. Walker Young, lawyer at the Scheef and Stone LLP in Frisco, Texas, is an analysis of a case that he is a part of.  During our last interview one of the biggest cases he highlighted was that of Michael Beal v. Pruvit Ventures, Inc..  This research assessment is simply an essay in preparation for my meeting with Mr. Young on Friday so I have a preliminary understanding of the case going in.  For this research paper I am planning on outlining the basic facts of the case and then explaining the arguments by both sides.  Mr. Young was on the side of Pruvit Ventures, Inc. who is the appellee in this case.  

 

This case was based on a contract, a mutual agreement between two parties that is legally binding.  In this case, Michael Beal was working as a sales representative under Pruvit Ventures and had his own subset business where he attracted clients for the company.  He was paid on a commission basis which was a steady source of income with the network he had established.  Part of the contract he had, however, stated that he was not able to attract customers or work for another company in the field for a certain amount of time after he left the company.  This extends to him being fired or leaving voluntarily.  This is called a non-compete section to the contract.  Mr. Beal had been suspected of breaking his non-compete in 2019 and the Pruvit company shut down his access to his business where he was bringing in money.  Beal would then resign from the company which arguably waived any compensation he had earned.  After leaving, Beal and two others would be found breaking their non-compete and Pruvit would file a lawsuit against all three parties.  This analysis focuses on Beal specifically.  Beal would file a counterclaim suit that he had been wrongfully compensated by the company.  The trial court would allow Pruvit to prevail in this case, ruling in a summary judgment that he had breached his contract and the company he had helped had committed tortious interference with the contract Beal had with Pruvit.  Beal would appeal to the Texas Supreme Court but would have his case struck down.

 

Starting off with the appellant’s argument, Beal’s team argued that there were four possible areas of error from the trial court but two main issues that I am going to discuss.  Firstly, he argued that they erred in granting Pruvit’s traditional motion for summary judgment and thus striking down Beal’s counterclaim which stated that Pruvit had broken the contract.  Secondly, Beal’s team argued that the court erred in not granting his no-evidence motion for summary judgment that would have allowed for favorable proceedings for Beal on the Pruvit suit.  Beal’s team argues throughout the case that by shutting down Beal’s Pruvit business access, Pruvit had breached their contract with Beal by revoking his ability to do his work on the basis of a suspension without evidence.  Beal would lose over $10 million from October, 2019 when Pruvit stopped paying him until his resignation.  They argued that this was grounds for Beal to leave the company in search of other work.  This argument is rooted in the first point and argues that Pruvit failed to meet their obligations to Beal, not the other way around.  Beal argues that there was no proof provided that he waived his right to compensation or legal measures against Pruvit either.  On the more defensive side, Beal argues that there is no proof or evidence that was provided throughout the case that showed a breach in the contract from Beal’s side.  He argues that without proof of him breaking his non-compete, Pruvit had no grounds to suspend him which would lead to his eventual resignation.  These two points were the basis of the Beal appeal and were the argument presented by his team in the case brief.  

 

The Pruvit side, the side where Mr. Young was working, worked to strike down all the points made by Beal in his argument.  Firstly, Pruvit argued that there was no need for evidence and suspicion alone was grounds to suspend Beal to conduct a form of investigation.  As Beal had already been suspended once before there was no reason for him to feel that he was wrongfully stripped of his means of work and compensation for missed time would have only been acceptable had he stayed with the company.  Not only did Beal continuously refer to his exit from Pruvit as a resignation, in both his resignation email and in multiple posts online and on social media, but he also highlighted the fact that he was well off and had more lucrative opportunities outside of Pruvit.  This shows that the resignation was not driven by a breach of contract like he suggests and highlights the two standing arguments against compensating Beal that Pruvit has.  These two arguments are waiver, that Beal waived his right to compensation and any other forms of suit by resigning which is outlined in the Pruvit Contract, and estoppel, that he cannot go back on his previous agreement to waive his right for compensation upon resignation.  They argue that the record on the trial case is not flawed and clearly shows how Beal’s arguments are irrelevant.  Despite this being a de novo standard of review where the appellate court will take a completely new view on the case, Pruvit was able to use many of the same arguments they made in trial court in order to strike down Beal in appellate court and win again.  This was probably also taken into consideration when the Texas Supreme Court decided not to review the case.

 

Understanding the basic information of a trial and appeal that I will possibly use in my final product is extremely important to my work in this class.  I will use what I have learned through this work in my interview with Mr. Young so it can be more productive and efficient as I already understand the basic arguments and points of the case.  This is an extremely interesting case and an example of how contracts have debatable standing and situational components are crucial in court and in appeals.

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