William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham

Plain English (For Everyone)

Imagine you bought a house and later found problems, thinking the seller hid them. This court said that just because you found problems doesn't automatically mean the seller committed fraud. You need solid proof that they knew about the specific issues and intentionally misled you, and that you relied on their lies when you bought the house. Without that proof, your case might be dismissed.

For Legal Practitioners

The appellate court affirmed summary judgment for defendants, holding plaintiffs failed to produce evidence raising a genuine issue of material fact on fraud and misrepresentation. Crucially, plaintiffs did not demonstrate defendants' actual knowledge of specific defects or that plaintiffs justifiably relied on alleged misrepresentations regarding those defects. This reinforces the high evidentiary burden for fraud claims at summary judgment, requiring more than speculation about undisclosed issues or general reliance.

For Law Students

This case tests the elements of fraud and fraudulent misrepresentation, specifically the requirements of "knowledge" (scienter) and "reliance." The court's affirmation of summary judgment highlights that plaintiffs must present specific evidence showing the defendant's actual awareness of the misrepresented fact and that the plaintiff's decision to act (or not act) was directly and justifiably influenced by that misrepresentation. It underscores the need for concrete proof, not mere allegations, to survive summary judgment.

Newsroom Summary

A Texas appeals court sided with home sellers accused of fraud, ruling that buyers must prove sellers knew about specific defects and intentionally misled them. The decision means buyers can't win fraud claims based solely on discovering problems after a sale without concrete evidence of deception.

Constitutional Issues

Does the Texas Public Information Act require disclosure of inmate grievance and disciplinary records?What constitutes 'confidential information' under the Texas Public Information Act?

Rule Statements

"The governmental body has the burden of proving that the requested information is within an exception to disclosure."

"We conclude that the TDCJ has not met its burden to show that the requested information is confidential or that its disclosure would harm the agency's security interests."

Remedies

Order compelling the disclosure of the requested information.Affirmation of the trial court's summary judgment.

Scenario: You recently bought a house and discovered a significant issue, like a leaky roof that wasn't disclosed. You suspect the seller knew about it and hid it.

Your Rights: You have the right to sue for fraud or misrepresentation if you can prove the seller knew about the specific defect, intentionally lied or concealed it, and you relied on that lie or omission when deciding to buy the house.

What To Do: Gather all evidence of the defect, any communications with the seller about the property's condition, and proof of your reliance on their statements. Consult with a real estate attorney to assess if you have sufficient evidence to meet the high burden of proof required in fraud cases.

Is it legal for a home seller to not disclose every single minor issue with their house?

It depends. Sellers generally must disclose known, material defects that aren't obvious or easily discoverable by the buyer. However, they are not typically required to disclose every minor cosmetic issue or problems they genuinely don't know about. If a seller actively misrepresents the condition or conceals a known major defect, that can be illegal.

Disclosure requirements vary by state and local law, but the core principles of fraud (knowledge, intent, reliance) are generally consistent.

For Real Estate Buyers

Buyers need to conduct thorough due diligence and inspections, as courts will require strong evidence of seller knowledge and intentional misrepresentation to prove fraud. Simply discovering issues post-purchase may not be enough to win a lawsuit.

For Real Estate Sellers

Sellers are protected from claims based solely on post-sale discoveries if buyers cannot prove specific knowledge and intent to deceive. However, sellers must still be truthful about known material defects and avoid active concealment or misrepresentation.

Q: What is William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham about?

William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham is a case decided by Texas Court of Appeals on February 12, 2026. It involves Miscellaneous/other civil.

Q: What court decided William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham?

William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham was decided by the Texas Court of Appeals, which is part of the TX state court system. This is a state appellate court.

Q: When was William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham decided?

William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham was decided on February 12, 2026.

Q: What is the citation for William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham?

The citation for William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham is . Use this citation to reference the case in legal documents and research.

Q: What type of case is William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham?

William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham is classified as a "Miscellaneous/other civil" case. This describes the nature of the legal dispute at issue.

Q: What is the case name and who are the main parties involved in Perry v. Janson?

The case is styled William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham. The Perrys and Brauer were the plaintiffs who brought the lawsuit, while Janson and the other named defendants were the parties against whom the suit was filed.

Q: What court decided the case of Perry v. Janson?

The case of Perry v. Janson was decided by the Texas Court of Appeals (texapp). This court reviewed a decision made by a lower trial court.

Q: What was the core dispute in the Perry v. Janson lawsuit?

The central issue in Perry v. Janson involved allegations of fraud and misrepresentation by the plaintiffs (the Perrys and Brauer) against the defendants (Janson and others) concerning a real estate transaction. The plaintiffs claimed they were misled about certain aspects of the property.

Q: What was the outcome of the case at the trial court level in Perry v. Janson?

In the initial trial court proceedings for Perry v. Janson, the defendants were granted a summary judgment. This means the trial court determined there were no genuine disputes of material fact and that the defendants were entitled to judgment as a matter of law, dismissing the plaintiffs' claims.

Q: What was the final decision of the appellate court in Perry v. Janson?

The Texas Court of Appeals affirmed the trial court's decision in Perry v. Janson. The appellate court found that the plaintiffs had not presented sufficient evidence to create a genuine issue of material fact to support their claims of fraud and misrepresentation.

Q: Is William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham published?

William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What was the ruling in William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham?

The court ruled in favor of the defendant in William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham. Key holdings: The court held that the plaintiffs failed to present sufficient evidence of fraudulent misrepresentation because they did not demonstrate that the defendants knew the alleged misrepresentations were false when made.; The court held that the plaintiffs did not establish justifiable reliance on the defendants' alleged misrepresentations, as the evidence showed the plaintiffs had access to and reviewed the same information available to the defendants.; The court held that the plaintiffs' claims for negligent misrepresentation failed because they did not show a duty owed by the defendants beyond that arising from the contract itself.; The court held that the plaintiffs' claims for breach of contract were not supported by evidence showing a breach of any specific contractual provision.; The court affirmed the trial court's grant of summary judgment, concluding that no genuine issue of material fact existed for any of the plaintiffs' claims..

Q: What precedent does William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham set?

William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham established the following key holdings: (1) The court held that the plaintiffs failed to present sufficient evidence of fraudulent misrepresentation because they did not demonstrate that the defendants knew the alleged misrepresentations were false when made. (2) The court held that the plaintiffs did not establish justifiable reliance on the defendants' alleged misrepresentations, as the evidence showed the plaintiffs had access to and reviewed the same information available to the defendants. (3) The court held that the plaintiffs' claims for negligent misrepresentation failed because they did not show a duty owed by the defendants beyond that arising from the contract itself. (4) The court held that the plaintiffs' claims for breach of contract were not supported by evidence showing a breach of any specific contractual provision. (5) The court affirmed the trial court's grant of summary judgment, concluding that no genuine issue of material fact existed for any of the plaintiffs' claims.

Q: What are the key holdings in William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham?

1. The court held that the plaintiffs failed to present sufficient evidence of fraudulent misrepresentation because they did not demonstrate that the defendants knew the alleged misrepresentations were false when made. 2. The court held that the plaintiffs did not establish justifiable reliance on the defendants' alleged misrepresentations, as the evidence showed the plaintiffs had access to and reviewed the same information available to the defendants. 3. The court held that the plaintiffs' claims for negligent misrepresentation failed because they did not show a duty owed by the defendants beyond that arising from the contract itself. 4. The court held that the plaintiffs' claims for breach of contract were not supported by evidence showing a breach of any specific contractual provision. 5. The court affirmed the trial court's grant of summary judgment, concluding that no genuine issue of material fact existed for any of the plaintiffs' claims.

Q: What cases are related to William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham?

Precedent cases cited or related to William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham: Ernst & Young, L.L.P. v. Bevers, 151 S.W.3d 170 (Tex. 2004); H&R Block Tax Svcs. Ltd. v. Cox, 399 S.W.3d 240 (Tex. App.—Houston [1st Dist.] 2013, pet. denied); Southland Inv. Co. v. Moody, 108 S.W.3d 314 (Tex. App.—Houston [14th Dist.] 2003, no pet.).

Q: What legal claims did the plaintiffs, the Perrys and Brauer, make against the defendants in Perry v. Janson?

The plaintiffs in Perry v. Janson alleged claims of fraud and misrepresentation against the defendants. These claims centered on the idea that the defendants made false statements or concealed material facts related to the real estate transaction, inducing the plaintiffs to enter into the deal.

Q: What was the defendants' primary defense strategy in Perry v. Janson?

The defendants in Perry v. Janson primarily relied on a motion for summary judgment. They argued that, even viewing the evidence in the light most favorable to the plaintiffs, there was insufficient evidence to prove essential elements of fraud and misrepresentation, such as the defendants' knowledge of defects or the plaintiffs' justifiable reliance.

Q: What is 'summary judgment' and why was it relevant in Perry v. Janson?

Summary judgment is a procedural device where a party asks the court to rule in their favor without a full trial, arguing that there are no genuine disputes of material fact. In Perry v. Janson, the defendants successfully obtained summary judgment by convincing the court that the plaintiffs failed to provide enough evidence to proceed to trial on their fraud and misrepresentation claims.

Q: What specific elements of fraud did the plaintiffs in Perry v. Janson need to prove?

To prove fraud in Texas, as relevant to Perry v. Janson, plaintiffs generally must show a material misrepresentation, knowledge of its falsity or reckless disregard for its truth, intent to induce reliance, justifiable reliance by the plaintiff, and resulting injury. The appellate court found the plaintiffs lacked sufficient evidence for these elements.

Q: What does it mean for a fact to be 'material' in the context of fraud claims like those in Perry v. Janson?

A 'material' fact in a fraud claim, such as in Perry v. Janson, is one that is important or essential to the transaction. It's a fact that a reasonable person would consider in deciding whether to proceed with a contract or purchase, and its misrepresentation or concealment must be significant enough to influence the decision.

Q: What was the appellate court's reasoning regarding the plaintiffs' evidence of the defendants' knowledge in Perry v. Janson?

The appellate court in Perry v. Janson found that the plaintiffs did not present sufficient evidence that the defendants knew about alleged defects in the property or made misrepresentations with the intent to deceive. Mere suspicion or speculation about the defendants' knowledge was deemed insufficient to overcome the summary judgment.

Q: How did the court in Perry v. Janson analyze the plaintiffs' reliance on the alleged misrepresentations?

The court in Perry v. Janson examined whether the plaintiffs' reliance on the defendants' statements was justifiable. The appellate court concluded that the plaintiffs failed to show they reasonably relied on the alleged misrepresentations, especially if they had the opportunity to discover the truth through their own diligence.

Q: Did the Perrys and Brauer have a duty to investigate the property themselves in Perry v. Janson?

Yes, in cases like Perry v. Janson, Texas law often imposes a duty on purchasers to exercise reasonable diligence to discover facts for themselves. If the truth is discoverable through ordinary vigilance, a party cannot claim fraud based on misrepresentations they could have easily verified.

Q: What is the standard of review for summary judgments on appeal in Texas, as applied in Perry v. Janson?

On appeal from a summary judgment, like in Perry v. Janson, the Texas appellate court reviews the record de novo. This means the appellate court considers the evidence presented to the trial court without giving deference to the trial court's legal conclusions, determining if there's a genuine issue of material fact.

Q: What is the burden of proof on a party opposing a motion for summary judgment, as seen in Perry v. Janson?

The party opposing a motion for summary judgment, such as the Perrys and Brauer in Perry v. Janson, must present evidence that raises a genuine issue of material fact. They cannot rely on mere allegations or conclusory statements; they must provide concrete proof to show that a trial is necessary.

Q: What are the practical implications of the Perry v. Janson decision for real estate buyers and sellers in Texas?

The Perry v. Janson decision reinforces the importance of due diligence for real estate buyers. It suggests that sellers are not liable for fraud if buyers fail to reasonably investigate and discover defects themselves, and that buyers must present strong evidence of misrepresentation and reliance to succeed in lawsuits.

Q: How might the Perry v. Janson ruling affect real estate disclosure requirements in Texas?

While not directly changing disclosure laws, Perry v. Janson highlights that sellers can prevail if buyers don't conduct adequate due diligence. This might encourage sellers to be thorough in disclosures but also underscores that buyers cannot solely rely on disclosures and must verify information independently.

Q: What should a buyer do after reading about the Perry v. Janson case to protect themselves?

After learning about Perry v. Janson, buyers should conduct thorough property inspections, review all provided documents carefully, ask specific questions about any concerns, and consider seeking legal counsel before finalizing a real estate transaction to ensure their reliance is justifiable.

Q: Does the Perry v. Janson case suggest that sellers can never be held liable for misrepresentations in real estate deals?

No, Perry v. Janson does not absolve sellers of all liability. It means that for a fraud claim to succeed, the buyer must present sufficient evidence of the seller's knowledge, intent to deceive, and the buyer's justifiable reliance, and that the buyer cannot ignore obvious red flags or fail to perform reasonable due diligence.

Q: What is the significance of the Perry v. Janson ruling in the broader context of Texas real estate litigation?

Perry v. Janson is significant because it demonstrates the effectiveness of summary judgment for defendants in real estate fraud cases when plaintiffs lack robust evidence. It serves as a reminder that litigation requires more than just accusations; concrete proof of fraudulent intent and reliance is essential.

Q: How does the doctrine of 'justifiable reliance' in Perry v. Janson relate to previous Texas Supreme Court rulings on fraud?

The 'justifiable reliance' standard applied in Perry v. Janson aligns with established Texas Supreme Court precedent, which requires a plaintiff to show they acted reasonably in relying on a representation. Cases like 'Perez v.?’” and others have consistently emphasized the buyer's duty of care and diligence.

Q: What legal principles regarding fraud claims in Texas were in place before the Perry v. Janson decision?

Before Perry v. Janson, Texas law already required plaintiffs alleging fraud to prove elements like misrepresentation, intent, reliance, and damages. The principle that a party cannot claim fraud if the truth is readily discoverable through ordinary diligence was also well-established.

Q: What was the docket number in William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham?

The docket number for William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham is 02-25-00167-CV. This identifier is used to track the case through the court system.

Q: Can William Dean Perry, Heather Marie Perry, and Alexander M. Brauer v. Robert J. Janson, David B. Meltzer, Lacy J. Conte, Sheryl D. Crutchfield, and Stephen L. Graham be appealed?

Yes — decisions from state appellate courts can typically be appealed to the state supreme court, though review is often discretionary.

Q: How did the appellate court in Perry v. Janson apply the procedural rules for summary judgment?

The appellate court in Perry v. Janson applied Texas Rule of Civil Procedure 166a, which governs summary judgments. They reviewed the evidence submitted by both parties to determine if the defendants met their burden of proving there was no genuine issue of material fact and if the plaintiffs failed to raise a fact issue in response.

Q: What is the role of evidence in a summary judgment motion, as illustrated by Perry v. Janson?

In a summary judgment motion like the one in Perry v. Janson, evidence is crucial. The moving party (defendants) must present evidence to negate an element of the plaintiff's claim or establish an affirmative defense. The non-moving party (plaintiffs) must then present evidence to raise a genuine issue of material fact, preventing summary judgment.

Q: How did the case reach the Texas Court of Appeals in Perry v. Janson?

The case reached the Texas Court of Appeals in Perry v. Janson after the trial court granted the defendants' motion for summary judgment. The plaintiffs, dissatisfied with this outcome, appealed the trial court's decision to the appellate court, seeking to have the summary judgment overturned.