in Re: Dale Works

CourtCourt of Appeals of Texas
DecidedOctober 17, 2003
Docket06-03-00120-CV
StatusPublished

This text of in Re: Dale Works (in Re: Dale Works) 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: Dale Works, (Tex. Ct. App. 2003).

Opinion

6-96-028-CV Long Trusts v. Dowd


In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana


______________________________


No. 06-03-00120-CV



IN RE:

DALE WORKS





Original Mandamus Proceeding








Before Morriss, C.J., Ross and Carter, JJ.

Opinion by Justice Ross



O P I N I O N


          In this original proceeding, Dale Works seeks a writ of mandamus directing the trial court to (1) withdraw an August 27, 2003, order denying Works' motion to disqualify attorney Ben Franks as opposing counsel, (2) enter an order granting Works' motion to disqualify Franks as opposing counsel, and (3) enter an order prohibiting Franks from communicating any privileged information to the new counsel. Based on the record and pleadings before us, and without hearing oral argument, we deny the petition.

I. Factual and Procedural Background

          Raymond and Delores Head married in 1996. On August 25, 1997, as they were walking down a street in Texarkana, Texas, Raymond and Delores were struck from behind by a car operated by Linda Burks, an employee of Budget Rent-A-Car. Raymond and Delores sued both Budget Rent-A-Car and Burks (collectively "Budget") for injuries they suffered in the accident. Franks represented both Raymond and Delores in the suit. According to Delores' testimony, Raymond's claims against Budget were resolved first, and it was not until later that Delores settled her claims against the company. This, according to Delores, resulted in two separate settlements: one for Raymond, and one for herself.

          On Thursday, February 13, 2003, Raymond died. His survivors include Delores, two daughters, Marla Hohner and Lori Tally, and a grandchild, Clayton Tally. In the copy of the will submitted for probate, Raymond named Works as the executor of his estate. The copy of the will seeks to devise Raymond's estate to his daughters and grandson, but makes no provision for Delores.

          Delores filed a contest to the will. Delores chose Franks, the attorney who represented her in the suit against Budget, as counsel of record in the will contest. In response, Works sought to have Franks disqualified on the basis that Franks' prior representation of Raymond is adverse to Delores' claims against Raymond's estate. Works also announced his plan to call Franks as a material witness in its defense of the will. Works contends Franks structured Raymond's and Delores' settlements separately pursuant to a premarital agreement. Franks' knowledge of a premarital agreement, according to Works, makes him an essential fact witness in the will contest. Should Works, as executor of the estate, not be able to bring forth a copy of the premarital agreement, and if the copy of the will submitted for probate is not approved by the probate court, Works hopes to show that Delores and Raymond nonetheless had a premarital agreement and that, therefore, Delores should receive none of Raymond's property that might otherwise be considered community property in the event Raymond died intestate.

          The trial court denied the estate's motion to disqualify Franks. Works now asks us to disqualify Franks as Delores' counsel.

II. The Applicable Standards

          A. Mandamus Relief

          Mandamus will issue only when the mandamus record establishes (1) a clear abuse of discretion or the violation of a duty imposed by law, and (2) the absence of a clear and adequate remedy at law. Cantu v. Longoria, 878 S.W.2d 131, 132 (Tex. 1994); Walker v. Packer, 827 S.W.2d 833, 839-40 (Tex. 1992). Mandamus is an extraordinary remedy that will issue only to correct a clear abuse of discretion or, in the absence of another statutory remedy, when the trial court fails to observe a mandatory provision conferring a right or forbidding a particular action. Abor v. Black, 695 S.W.2d 564, 567 (Tex. 1985). Mandamus may issue even on questions of first impression if, as a matter of law, the trial court erred in its analysis and reached an erroneous legal conclusion. Huie v. DeShazo, 922 S.W.2d 920, 927-28 (Tex. 1996).

          B. Attorney Disqualification

          A party seeking to disqualify an attorney must show the existence of a prior attorney-client relationship "in which the factual matters were so related to the facts in the pending litigation that it creates a genuine threat that confidences that were revealed to the former attorney will be revealed by that attorney to its present adversary." In re Cap Rock Elec. Coop., Inc., 35 S.W.3d 222, 230 (Tex. App.‒Texarkana 2000, orig. proceeding). This "substantial relationship" test is a product of common law and predates the Texas Rules of Disciplinary Conduct for attorneys. Id. When seeking disqualification, "[t]he movant has the burden of producing evidence of such specific similarities capable of being recited in the disqualification order." Id.

III. Analysis

          In the case now before us, the parties have supplied documents from the Budget lawsuit, transcripts of hearings on two separate motions to disqualify Franks, and documents related to the probate proceedings. The parties agree that Franks previously worked as Raymond's attorney in Raymond's claims against Budget. The parties disagree, however, on whether the substance of that prior lawsuit (and any information garnered from Franks' representation of Raymond during that period) bears a substantial relationship to the substance of the will contest.

          Texas courts have often looked to the disciplinary rules to decide disqualification issues. In re Meador, 968 S.W.2d 346, 350 (Tex. 1998). While the disciplinary rules are merely guidelines, not controlling standards, for court-ordered disqualification, the rules do provide reasonable guidance‒even in cases where an attorney may not have clearly violated one of its canons. Id. at 351; see also In re Bahn, 13 S.W.3d 865, 872 (Tex. App.‒Fort Worth 2000, orig. proceeding) (quoting Rule 3.08 extensively). Rule 3.08 of the Texas Disciplinary Rules of Professional Conduct states:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Flores v. Millennium Interests, Ltd.
185 S.W.3d 427 (Texas Supreme Court, 2005)
Marcus Cable Associates, L.P. v. Krohn
90 S.W.3d 697 (Texas Supreme Court, 2002)
In Re Cap Rock Electric Cooperative, Inc.
35 S.W.3d 222 (Court of Appeals of Texas, 2000)
In Re Meador
968 S.W.2d 346 (Texas Supreme Court, 1998)
Abor v. Black
695 S.W.2d 564 (Texas Supreme Court, 1985)
In Re Bahn
13 S.W.3d 865 (Court of Appeals of Texas, 2000)
Brown v. De La Cruz
156 S.W.3d 560 (Texas Supreme Court, 2004)
Brady v. Fourteenth Court of Appeals
795 S.W.2d 712 (Texas Supreme Court, 1990)
C & H NATIONWIDE, INC. v. Thompson
903 S.W.2d 315 (Texas Supreme Court, 1994)
Cantu v. Longoria
878 S.W.2d 131 (Texas Supreme Court, 1994)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
Owens-Corning Fiberglas Corp. v. Malone
972 S.W.2d 35 (Texas Supreme Court, 1998)
McKinney v. Blankenship
282 S.W.2d 691 (Texas Supreme Court, 1955)
Huie v. DeShazo
922 S.W.2d 920 (Texas Supreme Court, 1996)
In re Bay Area Citizens Against Lawsuit Abuse
982 S.W.2d 371 (Texas Supreme Court, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
in Re: Dale Works, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-dale-works-texapp-2003.