Carl R. Pruett and National American Insurance Company v. the Harris County Bail Bond, International Fidelity Insurance Company and Allegheny Casualty Company

CourtCourt of Appeals of Texas
DecidedApril 7, 2011
Docket01-09-00384-CV
StatusPublished

This text of Carl R. Pruett and National American Insurance Company v. the Harris County Bail Bond, International Fidelity Insurance Company and Allegheny Casualty Company (Carl R. Pruett and National American Insurance Company v. the Harris County Bail Bond, International Fidelity Insurance Company and Allegheny Casualty Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Carl R. Pruett and National American Insurance Company v. the Harris County Bail Bond, International Fidelity Insurance Company and Allegheny Casualty Company, (Tex. Ct. App. 2011).

Opinion

Opinion issued April 7, 2011

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00384-CV

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Carl R. Pruett and National American Insurance Company, Appellants

V.

The Harris County Bail Bond Board, Appellee

On Appeal from the 125th District Court

Harris County, Texas

Trial Court Case No. C-2002-09290A

O P I N I O N

This appeal involves a challenge to an award of attorneys’ fees pursuant to the Civil Rights AttorneysFees Award Act (42 U.S.C. § 1988) arising out of claims made against the Harris County Bail Bond Board under Title 42, Section 1983 of the United States Code. Appellants, Carl R. Pruett and National American Insurance Company (collectively, “Pruett”), bring two issues challenging the adequacy of the trial court’s award.  We also consider the trial court’s denial of Pruett’s motion to recuse.  We reverse and remand.

BACKGROUND

The Board Enacts Rules Regarding Bond Solicitation

In the 1990s, the Harris County Bail Bond Board (“the Board”) began receiving complaints concerning bail bond solicitation practices in the County.  Specifically, there were complaints about bondsmen (1) contacting defendants with unexecuted warrants thereby “tipping off” the defendants about their impending arrests and increasing risks of flight, destruction of evidence, and harm to crime victims and police officers; and (2) soliciting business by telephone during non-business hours.

In response, the Board passed two local rules governing the solicitation of bail bond business in Harris County.  Rule 24 prevented the solicitation of bond business from a defendant with an outstanding warrant.  Rule 25 placed time restrictions on the solicitation of bond business by prohibiting solicitation of bond business (1) within the first 24 hours after an arrest; and (2) during non-business hours. 

The State Court Trial Proceedings

Soon thereafter, the Board suspended the bonding license of appellant, Carl Pruett, for violating Rules 24 and 25.  Pruett and National American Insurance Company, the insurance and surety company for which Pruett acted as an agent, filed suit against the Board requesting declaratory and injunctive relief.  The trial court granted a temporary restraining order and then a temporary injunction to prevent the Board from enforcing its rules. 

The Interlocutory Appeal before this Court

The Board filed an interlocutory appeal, which this Court dismissed after the trial court granted Pruett a permanent injunction, thereby mooting the interlocutory appeal.  See Int’l Fid. & Ins. Co. v. Pruett, No. 01-02-00438-CV, 2002 WL 31839202 (Tex. App.—Houston [1st Dist.] Dec. 19, 2002, no pet.) (not designated for publication).

The 2nd Appeal before this Court

          The Board then appealed the permanent injunction to this Court.  This Court upheld the constitutionality of Rule 24 and the portion of Rule 25 that prevented the solicitation of bond business during non-business hours.  However, this Court concluded that the portion of Rule 25 that prohibited bondsmen from soliciting businesses within the first 24 hours after an arrest was an unconstitutional restraint on free speech.  See Harris Cnty. Bail Bond Bd. v. Pruett, 177 S.W.3d 260 (Tex. App.—Houston [1st Dist.] 2005, aff’d in part, rev’d in part, 249 S.W.3d 447 (Tex. 2008).

The Appeal to the Texas Supreme Court

The Board then appealed to the supreme court, which ultimately affirmed this Court’s holding as to the constitutionality of the “non-business hours” portion of Rule 25 and the unconstitutionality of the portion of rule 25 that prohibited the solicitation of bond business within the first 24-hours after arrest.  However, the supreme court reversed this Court’s judgment as to the Rule 24, holding that its prohibition against the solicitation of bond business from defendants with open warrants was also an unconstitutional restriction on free speech. See Pruett v. Harris Co. Bail Bond Bd., 249 S.W.2d 447, 460–61 (Tex. 2008).  The supreme court remanded the case to the trial court for further proceedings.

The Parallel Federal Court Proceeding

At the same time the present case was pending in the state court, a parallel proceeding was transpiring in the federal courts.  In the federal proceeding, Pruett and another bondsman challenged the constitutionality of state statutes that had been passed, which mirrored the Board rules that were the subject of the state court case.  See Pruett v. Harris Cnty. Bail Bond Bd., 499 F.3d 403, 407–08 (5th Cir. 2007).  The Fifth Circuit reached the same result as the Texas Supreme Court—it held that the prohibitions against soliciting bond business when a warrant was outstanding or within the first 24-hours after arrest were unconstitutional, but that the prohibition against “after-hours” solicitation was valid.  Id. at 416.  The Fifth Circuit also reversed the trial court’s award of “nominal” attorney’s fees after considering and rejecting the Board’s argument that “special circumstances” should preclude or reduce the plaintiffs’ recovery of attorneys’ fees.  Id. at 417–18.

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Related

Scham v. District Courts Trying Criminal Cases
148 F.3d 554 (Fifth Circuit, 1998)
Rutherford v. Harris County Texas
197 F.3d 173 (Fifth Circuit, 1999)
Pruett v. Harris County Bail Bond Board
499 F.3d 403 (Fifth Circuit, 2007)
Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Blanchard v. Bergeron
489 U.S. 87 (Supreme Court, 1989)
Missouri v. Jenkins Ex Rel. Agyei
491 U.S. 274 (Supreme Court, 1989)
Jerry Von Clark v. James Bruce Butler
916 F.2d 255 (Fifth Circuit, 1990)
Carmody v. State Farm Lloyds
184 S.W.3d 419 (Court of Appeals of Texas, 2006)
Vickery v. Vickery
999 S.W.2d 342 (Texas Supreme Court, 1999)
Harris County Bail Bond Board v. Pruett
177 S.W.3d 260 (Court of Appeals of Texas, 2005)
Downer v. Aquamarine Operators, Inc.
701 S.W.2d 238 (Texas Supreme Court, 1985)
Pruett v. Harris County Bail Bond Board
249 S.W.3d 447 (Texas Supreme Court, 2008)

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Carl R. Pruett and National American Insurance Company v. the Harris County Bail Bond, International Fidelity Insurance Company and Allegheny Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carl-r-pruett-and-national-american-insurance-company-v-the-harris-county-texapp-2011.