Board of Law Examiners of the State of Texas v. James Brian Allen

CourtCourt of Appeals of Texas
DecidedOctober 18, 1995
Docket03-95-00061-CV
StatusPublished

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Bluebook
Board of Law Examiners of the State of Texas v. James Brian Allen, (Tex. Ct. App. 1995).

Opinion

cv5-061

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN



NO. 03-95-00061-CV



Board of Law Examiners of The State of Texas, Appellant



v.



James Brian Allen, Appellee



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 353RD JUDICIAL DISTRICT

NO. 94-07537, HONORABLE MARGARET A. COOPER, JUDGE PRESIDING



The Board of Law Examiners ("Board") found James Brian Allen to be chemically dependent and recommended him for a probationary license to practice law in Texas. The district court reversed the decision, holding that the Board's order was not supported by substantial evidence. Because we find that substantial evidence does exist to support the Board's order, we will reverse the judgment of the district court.



BACKGROUND

Appellee James Brian Allen applied for admission to the State Bar of Texas on August 25, 1993. The Board of Law Examiners made a preliminary determination that Allen might suffer from chemical dependency based on certain disclosures Allen made in his Declaration of Intention to Study Law and in the application itself. Because of this determination, the Board was required to order Allen to submit to a treatment facility for a chemical dependency evaluation, and Allen was evaluated on December 3, 1993. See Tex. R. Governing Bar Admission 10(b)(1).

The Board held a hearing on April 22, 1994 to determine if Allen actually did suffer from chemical dependency. Notably, Allen conceded that there was sufficient evidence for the Board to make a preliminary determination of chemical dependency and thus to justify the hearing. At the hearing, the Board determined that Allen, in fact, suffers from chemical dependency and ordered that he be awarded a probationary license for a period of two years, subject to certain restrictions and conditions. These conditions included, among other things, abstinence from alcohol, obtaining psychiatric or psychological care, compliance with the Lawyer's Assistance Program, participation in Alcoholics Anonymous, and submission to random alcohol/drug screens.

Allen exercised his right to judicial review, and the district court found that the Board's order was not supported by substantial evidence. The district court remanded the case to the Board and ordered that the "Board immediately certify James Brian Allen to the Supreme Court of Texas for issuance of a regular license to practice law."



DISCUSSION

Appellant Board attacks the judgment of the district court by three points of error. In its first two points of error, the Board asserts that the trial court erred in setting aside the Board's order because: (1) the chemical dependency evaluation was properly before the Board for consideration, and (2) the order is supported by substantial evidence in the record even in the absence of the chemical dependency evaluation. In its third point, the Board asserts that the trial court abused its discretion by ordering the Board to certify Allen to the supreme court for issuance of a regular license to practice law.

We will initially address the Board's second point of error in which it argues that the trial court erred in setting aside its order because the order is supported by substantial evidence even in the absence of the chemical dependency evaluation. We note that, because of its supervisory role in the admission process, the Board is essential to preserving the integrity and character of the Texas Bar. Board of Law Examiners v. Stevens, 868 S.W.2d 773, 776 (Tex.), cert. denied, 114 S. Ct. 2676 (1994). The supreme court grants the Board considerable discretion to evaluate applicants based upon the promulgated admission standards. Id. at 776. Before it may recommend a person for a license, however, the Board must be convinced "that the person is of the moral character and of the capacity and attainment proper for that person to be licensed." Tex. Gov't Code Ann. § 82.004(c) (West 1988).

The Rules Governing Admission to the Bar of Texas (the "Rules"), which have the same effect as statutes, dictate that the Board shall complete an investigation and determine that an applicant possesses good moral character and fitness before that person shall be eligible for bar admission. Tex. R. Governing Bar Admission 4(a).



Fitness, as used in these Rules, is the assessment of mental and emotional health as it affects the competence of a prospective lawyer. The purpose of requiring an Applicant to possess this fitness is to exclude from the practice of law any person having a mental or emotional illness or condition which would be likely to prevent the person from carrying out duties to clients, courts or the profession. A person may be of good moral character, but may be incapacitated from proper discharge of his or her duties as a lawyer by such illness or condition.



Tex. R. Governing Bar Admission 4(c). When the Board makes a negative character and fitness determination, an applicant is entitled to judicial review of the Board's decision. See Tex. R. Governing Bar Admission 15(i). The reviewing court may affirm or remand the matter to the Board depending on whether or not the decision "is reasonably supported by substantial evidence." Tex. R. Governing Bar Admission 15(i)(5) (emphasis added).

The Administrative Procedure Act ("APA") does not govern Board procedures, however, reference to the APA sections which address the scope of judicial review under the substantial evidence rule is beneficial. See Stevens, 868 S.W.2d at 777 (citing Tex. Gov't Code Ann. §§ 2001.001-2001.902 (West 1995)). Under the APA, "a court may not substitute its judgment for the judgment of the state agency on the weight of the evidence on questions committed to agency discretion." Tex. Gov't Code Ann. § 2001.174 (West 1995); see Railroad Comm'n v. Pend Oreille Oil & Gas Co., 817 S.W.2d 36, 41 (Tex. 1991) (substantial evidence rule "prevents the court from usurping the agency's adjudicative authority even though the court would have struck a different balance"). A court may affirm the agency decision in whole or in part and must reverse or remand the agency's decision only if "the administrative findings, inferences, conclusions, or decisions are: . . . (E) not reasonably supported by substantial evidence considering the reliable and probative evidence in the record as a whole; or (F) arbitrary or capricious or characterized by abuse of discretion or clearly unwarranted exercise of discretion." Tex. Gov't Code Ann. § 2001.174; see also Stevens, 868 S.W.2d at 777-78 (quoting same statute). "Although substantial evidence is more than a mere scintilla, the evidence may actually preponderate against the decision of the agency and nonetheless amount to substantial evidence." City of El Paso v. Public Util. Comm'n,

Related

City of El Paso v. Public Utility Commission
883 S.W.2d 179 (Texas Supreme Court, 1994)
Board of Law Examiners v. Stevens
868 S.W.2d 773 (Texas Supreme Court, 1994)
RAILROAD COM'N v. Pend Oreille Oil & Gas Co., Inc.
817 S.W.2d 36 (Texas Supreme Court, 1991)

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Board of Law Examiners of the State of Texas v. James Brian Allen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-law-examiners-of-the-state-of-texas-v-jam-texapp-1995.