in Re: Carrie Beth Bennett

CourtCourt of Appeals of Texas
DecidedAugust 22, 2006
Docket14-06-00537-CV
StatusPublished

This text of in Re: Carrie Beth Bennett (in Re: Carrie Beth Bennett) 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: Carrie Beth Bennett, (Tex. Ct. App. 2006).

Opinion

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed August 22, 2006

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed August 22, 2006.

In The

Fourteenth Court of Appeals

____________

NO. 14-06-00537-CV

IN RE CARRIE BETH BENNETT, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

  M E M O R A N D U M   O P I N I O N

This is an original proceeding stemming from a divorce action.  Relator Carrie Beth Bennett seeks a writ of mandamus ordering the respondent, the Honorable K. Randall Hufstetler, presiding judge of the 300th District Court, Brazoria County, Texas, to vacate his order dated May 31, 2006, granting a motion to disqualify relator=s attorney.   We conditionally grant the writ.

Facts


Relator=s attorney in the divorce suit, Marion Allen, is also her father.  Real party in interest Jeremy Bennett, relator=s spouse, filed a motion to disqualify Allen, claiming he is a party to Abusiness relationships@ with Jeremy and was identified in relator=s discovery responses as a person with knowledge of relevant facts.  Jeremy also claimed that Allen has a conflict of interest because he represented the parties concerning a lease agreement on property which is at issue in the divorce.  After conducting a hearing, the trial court granted Jeremy=s motion to disqualify Allen, and relator filed this original proceeding.    

Standard of Review 

Mandamus is an extraordinary remedy that will issue to correct a clear abuse of discretion and, generally, only when the relator lacks an adequate appellate remedy.  In re Nitla S.A. de C.V., 92 S.W.3d 419, 422 (Tex. 2002).  A party lacks an adequate appellate remedy if his counsel is disqualified.  Id.  Because disqualification is considered a severe remedy that results in Aimmediate and palpable harm,@ courts hold that mandamus relief is available.  See Schwartz v. Jefferson, 930 S.W.2d 957, 959 (Tex. App.CHouston [14th Dist.] 1996, orig. proceeding). 

When alleging a trial court abused its discretion in resolving factual issues, a relator must show that the trial court could reasonably have reached only one decision.  See Walker v. Packer, 827 S.W.2d 833, 840 (Tex. 1992).  As to the determination of legal principles, an abuse of discretion occurs if the trial court clearly fails to analyze or apply the law correctly.  Id.   A trial court does not abuse its discretion if it bases its decision on conflicting evidence and some evidence supports its decision; however, an abuse of discretion occurs when the trial court=s decision is contrary to the only permissible view of the evidence.  See In re Barber, 982 S.W.2d 364, 366 (Tex. 1998); Walker, 827 S.W.2d at 840.

Discussion


In her petition, relator argues that the trial court abused its discretion in disqualifying Allen because Jeremy failed to present any evidence to support disqualification.  Relator asserts that the only actual ground for disqualification alleged by JeremyBBAllen=s co-ownership interest in a power washer that has disappearedBBis not supported by any evidence.  Further, she contends that even if Allen were called to testify, the power washer is not an essential issue in the divorce suit.  

In a disqualification case, our analysis begins with the premise that disqualification is a severe measure which can result in immediate harm because it deprives a party of his chosen counsel and disrupts court proceedings.  In re Nitla, 92 S.W.3d at 423.  Because of its severity, courts must adhere to Aan exacting standard so as to discourage the use of a motion to disqualify as a dilatory trial tactic.@  In re Butler, 987 S.W.2d 221, 224 (Tex. App.CHouston [14th Dist.] 1999, orig. proceeding).  The burden is on the movant to establish with specificity the grounds for disqualification.  See In re Sanders, 153 S.W.3d 54, 56 (Tex. 2004).  Mere allegations of unethical conduct or evidence showing a Aremote possibility of a violation of the disciplinary rules will not suffice under this standard.@  Id.


The Disciplinary Rules, although not controlling in disqualification decisions,  provide guidelines relevant to a disqualification determination.  See id.  In their briefs, both parties discuss Disciplinary Rule of Professional Conduct 3.08.  See Tex. Disciplinary R. Prof=l Conduct 3.08, reprinted in Tex. Gov=t Code, tit. 2, subtit. G app. A (Vernon 2005) (Tex. State Bar R. art. X, ' 9).  Under that rule, a lawyer is prohibited from acting as both an advocate and a witness in an adjudicatory proceeding when the lawyer is or may be a witness necessary to establish an essential fact.[1]  See id.; In re Sanders, 153 S.W.3d at 56.  But, the fact that a lawyer serves as both an advocate and a witness does not in itself compel disqualification.  In re Sanders, 153 S.W.3d at 57.  ADisqualification is only appropriate if the lawyer=s testimony is >necessary to establish an essential fact.=@  Id. (quoting Tex. Disciplinary R. Prof=l Conduct 3.08).  For this reason, the party seeking disqualification must demonstrate that the opposing lawyer=s dual roles as attorney and witness will cause that party actual prejudice.  Id. 

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Related

In Re Sanders
153 S.W.3d 54 (Texas Supreme Court, 2004)
In Re Butler
987 S.W.2d 221 (Court of Appeals of Texas, 1999)
Schwartz v. Jefferson
930 S.W.2d 957 (Court of Appeals of Texas, 1996)
In Re Nitla S.A. De C.V.
92 S.W.3d 419 (Texas Supreme Court, 2002)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
In Re Bristol-Myers Squibb Co.
975 S.W.2d 601 (Texas Supreme Court, 1998)
In Re Barber
982 S.W.2d 364 (Texas Supreme Court, 1999)

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