Formosa Plastics Corporation, Usa v. Kajima International, Inc.

CourtCourt of Appeals of Texas
DecidedNovember 10, 2004
Docket13-02-00385-CV
StatusPublished

This text of Formosa Plastics Corporation, Usa v. Kajima International, Inc. (Formosa Plastics Corporation, Usa v. Kajima International, Inc.) 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
Formosa Plastics Corporation, Usa v. Kajima International, Inc., (Tex. Ct. App. 2004).

Opinion





NUMBER 13-02-385-CV


COURT OF APPEALS


THIRTEENTH DISTRICT OF TEXAS


CORPUS CHRISTI - EDINBURG


FORMOSA PLASTICS

CORPORATION, USA,                                                                Appellant,


v.


KAJIMA INTERNATIONAL, INC.,                                               Appellee.

On appeal from the 135th District Court of Calhoun County, Texas.


O P I N I O N


Before Justices Hinojosa, Yañez, and Castillo

Opinion by Justice Yañez

          Following a jury trial in this suit for fraud, the trial court rendered judgment in favor of appellee, Kajima International, Inc. (“Kajima”). Appellant, Formosa Plastics Corporation, USA (“Formosa”), challenges the trial court’s judgment by nine issues. We sustain appellant’s third issue and hold that the trial court erred in refusing to disqualify Kajima’s expert witness, A. W. “Chip” Hutchison (“Hutchison”) and his firm, A. W. Hutchison & Associates, Inc., (“AWH”) on the basis of “side-switching.” Accordingly, we reverse the trial court’s judgment and remand for a new trial.

I. Background

          In 1993, Kajima sued Formosa for breach of contract, fraud, quantum meruit, and negligent representation arising from construction contracts for work Kajima performed at Formosa’s expansion plant project in Point Comfort, Texas. In 1997, following a jury trial, the trial court rendered judgment for Kajima for $5,591,066.65. Kajima appealed, contending, among other things, that the trial court erred in refusing to submit a broad form fraud question. This Court reversed and remanded to the trial court for a new trial. See Kajima Int’l, Inc. v. Formosa Plastics Corp., 15 S.W.3d 289, 294 (Tex. App.–Corpus Christi 2000, pet. denied).

          On remand, Kajima non-suited all of its claims except fraud. Following a jury trial, the trial court rendered judgment in favor of Kajima and awarded it $15,432,123.45 in actual damages, plus pre-judgment interest of $14,210,269.65 and $403,156.86 in costs. This appeal followed.

II. Disqualification of Kajima’s Expert Witness

A. Background Facts of “Side-Switching” Issue

          In its third issue, Formosa contends the trial court erred in refusing to disqualify Hutchison as Kajima’s expert witness because of “side-switching.” In 1993, Formosa’s former outside counsel, Jones, Day, Reavis & Pogue (“Jones Day”), retained Steve Huyghe, an associate of Hutchison’s at AWH, and AWH as Formosa’s consulting experts in connection with the Kajima lawsuit. On October 4, 1993, Huyghe and an associate met with lawyers at Jones Day to discuss the suit. Over the next few months, Huyghe and AWH performed work for Formosa. By the end of December 1993, Formosa had paid AWH $20,875.89 for work done on the Kajima case.

          In December 1993, Formosa transferred its defense from Jones Day to Porter & Hedges. On December 3, 1993, Huyghe met with lawyers from Jones Day and Porter & Hedges to discuss the case. In April 1994, Porter & Hedges told Huyghe that his work for Formosa was “on hold.”

          A few months later, in August 1994, Kajima’s lead counsel contacted Huyghe about AWH working on the case for Kajima. Huyghe notified Margaret Kelihar, an attorney at Jones Day, Formosa’s former counsel, that he had been contacted by Kajima. Kelihar testified she told Huyghe his knowledge and involvement in the case “would make it difficult for him to represent the other side” and advised him to notify Porter & Hedges. Huyghe did not notify Porter & Hedges or Formosa. Formosa did not learn that Hutchison and Brian Rogers (also of AWH) had been designated as Kajima’s testifying experts until September 19, 1995. Several weeks later, on October 4, 1995, Formosa filed a motion to strike Hutchison and AWH as Kajima’s expert witnesses for “side-switching.” Following a hearing, the trial court denied Formosa’s motion.

B. Kajima’s Arguments

          In response to Formosa’s “side-switching” argument, Kajima argues the trial court was not required to disqualify Hutchison because: (1) even though Formosa initially shared some non-confidential information with Huyghe, who worked for A. W. Hutchison of California, no conflict exists between the work initially performed by Huyghe for Formosa and the work later performed by Hutchison for Kajima because Hutchison worked for AWH, a separate corporate entity based in Atlanta; (2) any information given to Huyghe by Formosa was discoverable and thus was not confidential; (3) Formosa did not directly share confidential information with Hutchison or Huyghe; and (4) the attorney vicarious-qualification rules do not apply to expert firms.

C. Standard of Review and Applicable Law

          We review a trial court’s decision on whether to disqualify an expert witness for an abuse of discretion. See Koch Ref. Co. v. Jennifer L. Boudreaux MV, 85 F.3d 1178, 1181 (5th Cir. 1997). Disqualification of an expert that switches sides in a lawsuit is an issue of first impression in Texas. However, the Fifth Circuit has addressed the test courts should apply when determining whether to disqualify an expert witness who has previously been retained to consult with another party. See id.

          In Koch, the Fifth Circuit adopted the two-part test adopted by the majority of courts that have considered the issue: (1) was it objectively reasonable for the first party who claims to have retained the expert to conclude that a confidential relationship existed between that party and the expert; and (2) did the first party disclose any confidential or privileged information to the expert? Id.; see also, e.g., Turner v. Thiel, 553 S.E.2d 765, 768 (Va. 2001) (adopting and applying two-part test to disqualify expert in medical malpractice case); Mitchell v. Wilmore, 981 P.2d 172, 175-77 (Colo. 1999) (applying two-part analysis to disqualify car accident reconstruction expert); Nelson v. McCreary, 694 A.2d 897, 903-04 (D.C. 1997) (applying two-part test to deny disqualification of medical expert who had been paid by both sides, due to lack of confidential or privileged information).

          

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