In Re Bruce L. Jamison v. the State of Texas

CourtCourt of Appeals of Texas
DecidedOctober 24, 2024
Docket09-21-00223-CV
StatusPublished

This text of In Re Bruce L. Jamison v. the State of Texas (In Re Bruce L. Jamison v. the State of Texas) 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
In Re Bruce L. Jamison v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-21-00223-CV __________________

IN RE BRUCE L. JAMISON

__________________________________________________________________

Original Proceeding 284th District Court of Montgomery County, Texas Trial Cause No. 20-09-10625-CV __________________________________________________________________

MEMORANDUM OPINION

On July 23, 2021, the trial court imposed pre-trial discovery sanctions against

the attorney for the plaintiff in a commercial dispute case styled Trial Court Cause

Number 20-09-10625-CV, Southern Luxury Motorcars, LLC d/b/a Crave Luxury

Auto v. Karl Stomberg, et al. In a petition for a writ of mandamus, Relator Bruce L.

Jamison contends the trial court abused its discretion: (1) by finding that Jamison

violated prior discovery orders and imposing sanctions without considering the

merits of the plaintiff’s motion to dismiss the Real Parties’ counterclaim pursuant to

the Texas Citizens Participation Act (“TCPA”); (2) by imposing sanctions against

1 Jamison for violating June 23, 2021 discovery orders without evidence of bad faith;

and (3) by imposing extraordinarily excessive sanctions that were wholly

disproportionate in light of the circumstances.

On July 29, 2021, we stayed all enforcement of the challenged order and

requested a response from Real Parties in Interest Karl Stomberg and Kristin

Stomberg. The Stombergs filed their response but before the Court issued an

opinion, we abated this original proceeding due to a bankruptcy stay that affected

Trial Court Case Number 20-09-10625-CV. On July 11, 2024, we reinstated this

original proceeding and granted leave for the parties to file supplemental briefs.

Neither Jamison nor the Stombergs filed a supplemental brief. We conditionally

grant mandamus relief.

Background

Jamison’s client, Andrew Powers, applied to the trial court for an order of

involuntary windup of Southern Luxury Motorcars, LLC d/b/a Crave Luxury Auto

(“SLM”). See Tex. Bus. Org. Code Ann. § 11.314(1)-(2). In addition to the windup

application, Powers asserted claims against the Stombergs for fraud, theft,

conversion, fraudulent transfer, and other wrongful acts. Powers amended his

petition to sue in his individual capacity and derivatively on behalf of SLM. Powers

added related claims against the Stombergs’ business associates and their adult

children.

2 In February 2021, the Stombergs, individually and on behalf of SLM, together

with a third-party plaintiff, 54 Dyer, L.P., filed a counterclaim and third-party

petition against Powers, Powers’ father Dwight, and a business entity of Powers’,

Crave Luxury Investments, LLC and its d/b/a, Crave Luxury. The pleading asserted

counterclaims against Powers for theft and embezzlement, conversion, fraudulent

transfer, fraud, breach of fiduciary duty, misappropriation of trade secrets,

racketeering, tortious interference with contracts and prospective and continuing

business relations, unfair competition and misappropriation by passing off, federal

communications acts violations, and conspiracy.

On June 8, 2021, the Stombergs filed a motion to compel discovery. On June

23, 2021, the trial court granted in part the motion to compel against Powers

individually and derivatively on behalf of SLM and ordered him to respond to 45

separate interrogatories and requests for production, as modified by the trial court’s

order, by July 16, 2021.

On June 24, 2021, the Stombergs filed a supplemental counterclaim in their

own behalf and on behalf of SLM. The Stombergs alleged that on June 23, 2021,

Powers sent an email addressed to all current and potential motor vehicle customers

and wholesalers, in which Powers warned the reader to be aware of fraudulent and

unlawful practices of Karl Stomberg, that Karl Stomberg had stolen funds and

defrauded at least one of SLM’s consignment customers, and advised all motor

3 vehicle vendors, auction houses, wholesalers, and distributors to be aware of Karl

Stomberg’s fraudulent and unlawful business practices. The Stombergs alleged the

statements were false and defamatory per se, that Powers published disparaging

words about the economic interests of Stomberg and SLM with malice and without

privilege, and that Powers willfully and intentionally interfered with the contracts

and business relations between SLM and its customers.

On July 16, 2021, Powers filed a motion pursuant to the TCPA to dismiss the

Stombergs’ supplemental counterclaim, including their claims against Powers for

defamation, business disparagement and tortious interference.

On July 19, 2021, the Stombergs filed an emergency motion to compel

discovery and for sanctions for Powers’ refusal to comply with the trial court’s June

23, 2021, order compelling discovery. In this motion, the Stombergs complained that

Jamison’s co-counsel relied on Powers’ TCPA motion to excuse Powers’ non-

compliance with the discovery order’s July 16, 2021, compliance deadline. The

Stombergs asserted that the attorney who signed Powers’ TCPA motion failed to

comply with Texas Rule of Civil Procedure 13, as his co-counsel’s email to the

Stombergs’ lawyer revealed that the motion had been filed only to release them from

complying with the discovery order before a scheduled mediation. The Stombergs

argued the TCPA motion was filed for the improper purposes of avoiding

compliance with the discovery order, there was no basis advanced for the effect

4 Powers gave to the TCPA motion, and there was no evidentiary support for the

TCPA motion. The Stombergs urged the trial court to use its inherent power to

impose sanctions for conduct that significantly interfered with core judicial

functions. The Stombergs asked the trial court to order Powers and Jamison’s law

firm to each pay SLM sanctions in the amount of $25,000, order Powers to produce

the documents previously ordered or face dismissal of all of Powers’ claims with

prejudice, and order that Powers pay SLM $2,500 in reasonable attorney’s fees for

the exchange of emails with Powers’ counsel and the preparation of the motion for

sanctions.

On July 22, 2021, in a supplement to their motion to compel, the Stombergs

stated they were also seeking sanctions under Texas Rule of Civil Procedure 215.2

for abuse of the discovery process. The Stombergs asked the trial court to order that

discovery on claims other than the defamation claim is not suspended by the TCPA

Motion to Dismiss, order Powers to produce the documents by July 24, 2021, order

Powers and Jamison’s law firm to each pay SLM $3,325 as one-half of the

reasonable attorney’s fees for preparing the motions, and hold Powers and Jamison’s

law firm in contempt of court and direct them to pay a $500 fine.

In response, Powers and Jamison’s law firm argued that by operation of

section 27.003(c), Powers’ TCPA motion suspended discovery in the entire case,

subject to discovery limited to the TCPA motion to dismiss as allowed by the trial

5 court upon a showing of good cause. Powers argued the TCPA provides the

exclusive remedy for frivolous motions to dismiss and that the court cannot deviate

from the mandatory statutory process for adjudicating TCPA motions. Powers

argued imposing sanctions under Rule 215 would violate due process because the

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