Heslin v. Jones

CourtUnited States Bankruptcy Court, S.D. Texas
DecidedOctober 19, 2023
Docket23-03035
StatusUnknown

This text of Heslin v. Jones (Heslin v. Jones) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heslin v. Jones, (Tex. 2023).

Opinion

October 19, 2023 UNITED STATES BANKRUPTCY COURT Nathan Ochsner, Clerk SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

IN RE: § § CASE NO: 22-33553 ALEXANDER E. JONES, § § CHAPTER 11 Debtor. § § NEIL HESLIN, et al., § § § v. § ADVERSARY NO. 23-03035 § ALEXANDER E. JONES, § § Defendant. §

MEMORANDUM DECISION ON TEXAS PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AGAINST JONES

Plaintiffs are parents of children murdered in the Sandy Hook Elementary School tragedy. Before this bankruptcy case started, they sued Alexander E. Jones and other defendants in Texas state court for defamation and intentional infliction of emotional distress. The Texas state court lawsuits are referred to here as the “Heslin/Lewis Action” and the “Pozner/De La Rosa Action.” About three years into both Actions, a state court entered default judgment orders against Jones based on repeated violations of discovery orders. These orders made Jones liable for the defamation and emotional distress claims. And, under Texas law, the orders also deemed Jones to have admitted all allegations in the Plaintiffs’ state court petitions. A jury in the Heslin/Lewis Action later awarded those Plaintiffs over $49 million in compensatory and exemplary damages. There has been no damages trial in the Pozner/De La Rosa Action. Jones and an entity he owns named Free Speech Systems, LLC filed separate bankruptcy cases in 2022. Free Speech elected to proceed under Subchapter V of the Bankruptcy Code. Jones is in a traditional chapter 11 case, not Subchapter V. This decision involves Jones’s case only. The Bankruptcy Code provides that some debts are excepted from a bankruptcy “discharge” and remain enforceable against the debtor even after a bankruptcy case ends. Plaintiffs started this adversary proceeding seeking an order stating that debts related to the state court actions are excepted from discharge under § 523(a)(6) of the Bankruptcy Code. They also believe that the state court record, including court orders and jury awards, prove that there are no material issues of disputed fact and that summary judgment is warranted as a matter of law. Jones disagrees. After careful consideration, the Court grants partial summary judgment. Background I. The Texas State Court Actions In 2018, Neil Heslin started the lawsuit captioned Heslin v. Jones, et al., Case No. D-1-GN-18-001835, in the 261st Judicial District Court of Travis County, Texas. That same year, Scarlett Lewis started the lawsuit captioned Lewis v. Jones, et al., Case No. D-1-GN-18-006623, in the 98th Judicial District Court of Travis County, Texas. These cases were later consolidated (the “Heslin/Lewis Action”). Heslin and Lewis sued Jones and Free Speech alleging defamation, defamation per se, and intentional infliction of emotional distress.1 Leonard Pozner and Veronique De La Rosa later started the lawsuit captioned Pozner and De La Rosa v. Jones, et al., Case No. D-1-GN-18-001842, in the 345th Judicial District Court of Travis County, Texas (the “Pozner/De La Rosa Action”), alleging the same causes of action against Jones and Free Speech as Heslin and Lewis.2 Jones does not contest that he answered the petitions in both Actions.3 But in September 2021, the 459th District Court granted Lewis a default judgment under Texas Rule of Civil Procedure 215 (“Rule 215”) against Jones and Free Speech for, among other things, intentionally disobeying a prior court discovery order.4

1 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Ex. 8 at 21–27, ECF No. 29-8. 2 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Ex. 4 at 18–25, ECF No. 29-4. 3 Def.’s Resp. to Mot. for Summ. J. at 29, ECF No. 32; MSJ Hr’g Tr. 69:1-7, 70:13-17, ECF No. 43. 4 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Ex. 42 at 4, ECF No. 29-42. Tex. R. Civ. P. 215.2 provides that if a party fails to comply with proper discovery requests or to obey an order to provide or permit discovery, ... the court in which the action is pending may, after notice and hearing, make such orders in regard to the failure as are just, and among others: (5) an order striking out pleadings or parts thereof . . . or dismissing with or without prejudice the action or proceedings or any part thereof, or rendering a judgment by default against the disobedient party. (emphasis added). TEX. R. CIV. P. 215.2(b)(5). In October 2021, the 459th District Court also granted a Rule 215 default judgment against Jones and Free Speech in the Pozner/De La Rosa Action because they “unreasonably and vexatiously” disregarded their discovery duties.5 That same month, the 261st District Court entered a Rule 215 default judgment against Jones and Free Speech in the Heslin case.6 The court found that both Jones and Free Speech showed “flagrant bad faith and callous disregard for the responsibilities of discovery under the rules.”7 The Heslin/Lewis Action proceeded to a jury trial before the 261st District Court on damages for Heslin’s defamation claim and the intentional infliction of emotional distress claims for both Heslin and Lewis. After a multi-day trial, the state court issued one “Charge of the Court” for compensatory damages and another for exemplary damages.8 The following chart summarizes the jury charges:9 Defamation Against Neil Heslin Intentional Infliction of Emotional Distress You are instructed that Defendants Alex You are instructed that Defendants Jones and Free Speech Systems, LLC Alex Jones and Free Speech Systems, committed defamation against Neil LLC committed intentional infliction of Heslin. emotional distress against Neil Heslin and Scarlett Lewis in a continuing You are further instructed that course of conduct from 2013 to 2018. Defendants Alex Jones and Free Speech Systems, LLC published statements that Intentional infliction of emotional were false and defamatory concerning distress means the defendant acts Neil Heslin on June 26, 2017 and July intentionally or recklessly with 20, 2017. extreme and outrageous conduct to cause the plaintiff emotional distress

5 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Ex. 41 at 2, ECF No. 29-41. 6 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Ex. 3, ECF No. 29-3. 7 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Ex. 3 at 3, ECF No. 29-3. 8 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Exs. 5, 6. ECF Nos. 29-5, 29-6. 9 Decl. of Stuart R. Lombardi in Supp. of Pls. Heslin, Lewis, Pozner and De La Rosa’s Mot. for Summ. J. Ex. 5, at 4, 6; Ex. 6 at 4, 6. ECF Nos. 29-5, 29-6. You are further instructed that and the emotional distress suffered by Defendants Alex Jones and Free Speech plaintiff was severe. Systems, LLC knew or should have

known, in the exercise of ordinary care, that the statements published on June 26, 2017 and July 20, 2017 were false and had the potential to be defamatory. You are further instructed that at the time Defendants Alex Jones and Free Speech Systems, LLC published the statements on June 26, 2017 and July 20, 2017, Defendants knew the statements were false as it related to Neil Heslin, or that Defendants published the statements with a high degree of awareness that they were probably false, to an extent that Defendants in fact had serious doubts as to the truth of the statements.

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