Danielle Sposito v. Linda Rollins-Threats, Ph.D.

CourtCourt of Appeals of Texas
DecidedJuly 10, 2024
Docket05-23-00597-CV
StatusPublished

This text of Danielle Sposito v. Linda Rollins-Threats, Ph.D. (Danielle Sposito v. Linda Rollins-Threats, Ph.D.) 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.

Bluebook
Danielle Sposito v. Linda Rollins-Threats, Ph.D., (Tex. Ct. App. 2024).

Opinion

Affirmed and Opinion Filed July 10, 2024

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-23-00597-CV

DANIELLE SPOSITO, Appellant V. LINDA ROLLINS-THREATS, PH.D., Appellee

On Appeal from the County Court at Law No. 4 Dallas County, Texas Trial Court Cause No. CC-22-05777-D

MEMORANDUM OPINION Before Justices Partida-Kipness, Pedersen, III, and Carlyle Opinion by Justice Partida-Kipness Appellant Danielle Sposito appeals the dismissal of her suit against Appellee

Dr. Rollins-Threats under Texas Rule of Civil Procedure 91a. In three issues, Sposito

asserts the trial court erred in: (1) granting the motion to dismiss; (2) awarding

attorney’s fees; and (3) denying Sposito’s motion to reconsider. We affirm.

BACKGROUND

Sposito’s lawsuit arises from Dr. Rollins-Threats’s involvement in a suit

affecting the parent-child relationship (SAPCR).1 Sposito is the grandmother of the

1 See TEX. FAM. CODE § 101.032(a). children at issue in the SAPCR. The SAPCR court appointed Dr. Rollins-Threats as

a parenting facilitator, in accordance with the parties’ agreement. In that role, Dr.

Rollins-Threats visited with the parties, issued reports for the court, and gave

testimony at several hearings.

Displeased with the SAPCR outcome, Sposito filed the present suit against

Dr. Rollins-Threats. In a single-page petition, Sposito asserted claims for

malpractice, “child endangerment,” and slander. Sposito alleged Dr. Rollins-Threats

was the parenting facilitator in the SAPCR case, and in that role she “[broke] both

state and federal laws,” “told multiple lies,” and “violated [Sposito’s] rights.”

Sposito’s petition provided no additional detail regarding these claims.

Dr. Rollins-Threats answered and included the affirmative defense of derived

judicial immunity in her role as a court-appointed parenting facilitator. Dr. Rollins-

Threats moved to dismiss under Rule 91a, asserting Sposito’s claims had no basis in

law because of the immunity defense. Dr. Rollins-Threats also sought attorney’s

fees.

In response, Sposito asserted Dr. Rollins-Threats was not entitled to immunity

because she was not appointed as parenting facilitator in the SAPCR suit, and in any

event Dr. Rollins-Threats had lied and broken various laws in her role as facilitator.

The parties engaged in additional briefing related to the Rule 91a motion. The trial

court held a hearing and later granted the motion to dismiss and awarded Dr. Rollins-

–2– Threats attorney’s fees. Sposito filed a motion to reconsider which was overruled by

operation of law. This appeal followed.

STANDARD OF REVIEW

We review the merits of a Rule 91a ruling de novo. San Jacinto River Auth.

v. Medina, 627 S.W.3d 618, 628 (Tex. 2021). The availability of a remedy under the

facts alleged is a question of law and the rule’s factual-plausibility standard is akin

to a legal-sufficiency review. City of Dallas v. Sanchez, 494 S.W.3d 722, 724 (Tex.

2016).

ANALYSIS

In three issues, Sposito asserts the trial court erred in: (1) granting the motion

to dismiss; (2) awarding attorney’s fees; and (3) denying Sposito’s motion to

reconsider. We address each issue in turn.

I. The Trial Court Did Not Err in Granting the Motion to Dismiss

In her first issue, Sposito asserts the trial court erred in granting the Rule 91a

motion to dismiss. We disagree.

A. Rule 91a

Under Rule 91a, party may move to dismiss a cause of action on the grounds

it has no basis in law or fact. TEX. R. CIV. P. 91a.1. A cause of action has no basis in

law if the allegations, taken as true, together with inferences reasonably drawn from

them, do not entitle the claimant to the relief sought. Id. A cause of action has no

basis in fact if no reasonable person could believe the facts pleaded. Id. Except on

–3– issues of costs and attorney’s fees, the court may not consider evidence in ruling on

the motion and must decide it based solely on the pleading of the cause of action,

together with any pleading exhibits permitted by Rule 59. TEX. R. CIV. P. 91a.6.

Rule 91a provides a harsh remedy and should be strictly construed. Renate

Nixdorf GmbH & Co. KG v. TRA Midland Props., LLC, No. 05-17-00577-CV, 2019

WL 92038, at *10 (Tex. App.—Dallas Jan. 3, 2019, pet. denied) (mem. op.) (citing

Gaskill v. VHS San Antonio Partners, LLC, 456 S.W.3d 234, 238 (Tex. App.—San

Antonio 2014, pet. denied)).

1) “No Basis in Fact”

The “no basis in fact” prong of Rule 91a.1 relates to the believability of the

facts alleged by a plaintiff in pleading a cause of action and, thus, seldom rises to a

point of contention in the case law. Long v. Long, 681 S.W.3d 805, 816–17 (Tex.

App.—Dallas 2023, no pet.). The “no basis in fact” prong is a “factual plausibility

standard.” Id. (citing Sanchez, 494 S.W.3d at 724). We do not consider whether such

allegations are likely, or even if the conduct alleged is outlandish, but only if a

reasonable person could believe the alleged conduct. Longhorn Creek Ltd. v.

Gardens of Connemara Ltd., 686 S.W.3d 418, 425 (Tex. App.—Dallas 2024, pet.

filed) (quoting Drake v. Walker, No. 05-14-00355-CV, 2015 WL 2160565, at *3

(Tex. App.—Dallas May 8, 2015, no pet.) (mem. op.)).

–4– 2) “No Basis in Law”

A cause of action alleged by a claimant has no basis in law “if the allegations,

taken as true, together with inferences reasonably drawn from them, do not entitle

the claimant to the relief sought.” TEX. R. CIV. P. 91a.1. In assessing whether the

non-movant’s pleading has no basis in law, we apply a fair-notice pleading standard

to determine whether the allegations of the petition are sufficient to allege a cause

of action. Long, 681 S.W.3d at 817 (citations omitted). A petition is sufficient if it

gives fair and adequate notice of the facts upon which the pleader bases his claim.

Id. “Even the omission of an element is not fatal if the cause of action may be

reasonably inferred from what is specifically stated.” Thomas v. 462 Thomas Fam.

Props., LP, 559 S.W.3d 634, 639 (Tex. App.—Dallas 2018, pet. denied) (quoting In

re Lipsky, 460 S.W.3d 579, 590 (Tex. 2015) (orig. proceeding)). Under this standard,

courts assess whether an opposing party can ascertain from the pleading the nature

of the controversy, its basic issues, and the type of evidence that might be relevant.

Id. at 640.

In applying the fair-notice pleading standard to our review in a Rule 91a

context, “we must construe the pleadings liberally in favor of the plaintiff, look to

the pleader’s intent, and accept as true the factual allegations in the pleadings to

determine if the cause of action has a basis in law or fact.” Longhorn Creek, 686

S.W.3d at 426 (quoting In re RNDC Tex., LLC, No. 05-18-00555-CV, 2018 WL

2773262, at *1 (Tex. App.—Dallas June 11, 2018, no pet.) (mem. op.)). “[I]f nothing

–5– in the pleading itself triggers a clear legal bar to the claim, then there is a basis in

law and the motion should be denied.” Id.

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