The Texas Court of Appeals recently issued a ruling in the case of Connected Solar, LLC v. Joshua Winchell, which involves a dispute over a solar panel installation contract. The court modified a previous default judgment against Connected Solar, impacting the damages awarded to Winchell. This case highlights the legal complexities surrounding contract disputes and consumer protection laws.
The case began when Joshua Winchell contracted with Connected Solar in September 2023 to purchase and install a residential solar panel system. After securing necessary approvals from his electric company, Winchell faced delays when Connected Solar failed to install the system or provide the agreed-upon components. In June 2024, Winchell filed a lawsuit against the company, alleging breach of contract and violations of the Texas Deceptive Trade Practices Act (DTPA).
Connected Solar was served with the lawsuit but did not respond, leading Winchell to request a default judgment. A hearing was scheduled for December 2024, but Connected Solar claimed it was not notified of the hearing. The trial court ultimately ruled in favor of Winchell, awarding him $89,645.16 in actual damages and an additional $268,935.48 in treble damages under the DTPA.
Connected Solar appealed the default judgment, challenging the amounts of damages awarded and the sufficiency of evidence supporting the DTPA claims. The case reached the Texas Court of Appeals, which reviewed the trial court's decision.
The court, led by Justice H. Todd McCray, ruled on July 31, 2026, affirming the judgment in part but also modifying it. The court found that the actual damages award should be reduced to $80,680.64, reflecting the amount Winchell had paid for the contract. The court stated, "We conclude the actual damages award should be reduced to $80,680.64." Additionally, the court reversed the prejudgment interest award, determining it should be modified to $2,813.74.
One of the key issues in the appeal was the award of treble damages under the DTPA. The court found that Winchell did not provide sufficient evidence to support the claim that Connected Solar knowingly or intentionally violated the DTPA. The court noted, "Absent such evidence, Winchell cannot demonstrate the foreknowledge or intent required for enhanced damages under section 17.50(b)(1)." As a result, the court reversed the portion of the judgment awarding unliquidated damages under the DTPA and remanded the case for a new trial on that issue.
This ruling has significant implications for both parties. For Connected Solar, the court's decision to reduce the damages and reverse the award of treble damages may lessen their financial liability. On the other hand, Winchell will need to present additional evidence in a new trial to support his claims for enhanced damages.
The case also underscores the importance of proper legal procedures in contract disputes. Default judgments, while sometimes necessary, are disfavored under Texas law. The court emphasized that any doubts about such judgments should be resolved against the party that secured the default. This principle serves to protect defendants' rights and ensure fair legal processes.
Looking ahead, the case may still have further developments as it is remanded for a new trial regarding unliquidated damages. This means that the parties will have another opportunity to present their arguments and evidence in court. Details about the timeline for the new trial were not available in the court filing.
In conclusion, the Texas Court of Appeals' ruling in Connected Solar, LLC v. Joshua Winchell reflects the complexities of contract law and consumer protection in Texas. The case highlights the importance of due process and the need for clear evidence in legal disputes over damages.