in Re William J. Skepnek

CourtCourt of Appeals of Texas
DecidedOctober 15, 1998
Docket03-98-00388-CV
StatusPublished

This text of in Re William J. Skepnek (in Re William J. Skepnek) 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 William J. Skepnek, (Tex. Ct. App. 1998).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-98-00388-CV

In re William J. Skepnek, Relator


ORIGINAL PROCEEDING FROM TRAVIS COUNTY
PER CURIAM

William Skepnek, an attorney for Raymark Industries, a bankrupt former defendant in asbestos-exposure litigation, was assessed sanctions totaling $110,000 for knowingly submitting false affidavits and special appearances based thereon in ten cases in the trial court. In this original proceeding, Skepnek seeks a writ of mandamus to have the sanctions vacated and a writ of prohibition issued to prevent the trial court from sanctioning him for filing the special appearances. We will grant the petition in part and conditionally issue the writ of mandamus as to $100,000 of the sanctions, but will deny the petition as to $10,000 of the sanctions. We will deny the request for the writ of prohibition.

Raymark filed special appearances in nine asbestos exposure cases that had been filed before September 1, 1995, some as late as August 31, 1995. (The tenth case in which sanctions were ordered was filed after September 1, 1995, but the real parties in interest ("plaintiffs") have admitted that Raymark did not file a special appearance in that case and plaintiffs have requested the trial court withdraw the sanctions in that case.) Raymark, however, did not become a defendant in these cases until plaintiffs filed amended petitions after September 1, 1995.

The special appearances were supported by affidavits from Raymark president James Cobb. He swore, based on his personal knowledge, that the company never paid Texas taxes, never had a license to do business in Texas, and never had an office, employees, bank accounts, or property in Texas.

Subsequent depositions of Cobb and Raymark chief executive officer Craig Smith exposed these statements as inaccurate. Cobb testified that he did not have personal knowledge of the averments in his affidavit and that he relied on Smith's representations. Smith's testimony showed that Raymark and its predecessors had the jurisdiction-establishing contacts with Texas that Cobb denied in his affidavit.

Despite attending the depositions at which the statements in the affidavits were disavowed, Raymark never withdrew the special appearances and Skepnek later filed a brief in support of the special exceptions, urging the jurisdiction-defeating assertions from the discredited affidavit. Plaintiffs sought sanctions against Raymark and Skepnek for filing and pursuing the special appearances and supporting materials.

The court set a hearing on the plaintiffs' motion for sanctions against Raymark and its attorney, Skepnek. Shortly before the hearing, Raymark declared bankruptcy. Believing the hearing would be subject to the automatic stay on proceeding on claims against a bankrupt party, Skepnek did not attend. In his absence, the trial court held the hearing on the motion for sanctions against Skepnek. The sanctions order recites that the plaintiffs did not seek sanctions against Raymark.

The court imposed sanctions under both Texas Civil Practice and Remedies Code section 10.004(c)(2) and Texas Rule of Civil Procedure 13. The $100,000 Code sanction was imposed for "knowingly proffering an affidavit known by Skepnek to be false." The Rule 13 sanctions were $10,000 compensation to plaintiffs for attorney's fees accrued in having to respond to the special appearance and present the motion for sanctions.

Skepnek challenges both sanctions by this petition for writ of mandamus. We will not address the sanction in trial court cause of action No. 96-15405 because the plaintiffs have admitted that the sanction is unwarranted and have requested that it be withdrawn.

A threshold issue is whether we can consider this petition for writ of mandamus while the underlying suit continues. We conclude mandamus review is appropriate when a relator alleges that plainly unauthorized sanctions are payable immediately, the plaintiffs have filed a notice of nonsuit on their claims against the sanctioned attorney's client, and the suit continues as to other parties. Ordinarily, mandamus review is not appropriate if the relator has an adequate remedy by appeal. Bell Helicopter Textron, Inc. v. Walker, 787 S.W.2d 954, 955 (Tex.1990). Though persons assessed monetary sanctions payable at judgment have remedy only by appeal, the supreme court has allowed mandamus review of monetary sanctions that are payable immediately and that are so severe that they impair the party's ability to proceed with the litigation. Braden v. Downey, 811 S.W.2d 922, 929 (Tex. 1991). The sanctions in the present case do not prevent litigation because the plaintiffs' notice of nonsuit indicates the end of this litigation against Raymark. However, the sanctions order requires immediate payment by Skepnek even though the litigation will continue against other defendants with the final judgment at some undetermined time. Thus, without mandamus review, Skepnek will be deprived of his money until the uncertain date of final judgment for these cases, even though his client is no longer part of the suit. This, combined with the allegation that at least part of the sanctions order is not statutorily permissible, tips the scale in favor of considering his petition for writ of mandamus.



Sanctions under Civil Practice and Remedies Code chapter 10

We first consider the sanctions based on the Code violation. The historical note to section 10.001 quotes the enacting legislation:

This Act takes effect September 1, 1995, and applies only to a pleading or motion in a suit commenced on or after that date. A pleading or motion in a suit commenced before the effective date of this Act is governed by law applicable to the pleading or motion immediately before the effective date of this Act, and that law is continued in effect for that purpose.



Tex. Civ. Prac. & Rem. Code Ann. § 10.001 (West Supp. 1998) (emphasis supplied). Nine of the cases were filed before September 1, 1995, some as late as August 31, 1995; in the only case filed after September 1, 1995, plaintiffs have requested the sanction be withdrawn because no special appearance was filed.

Plaintiffs argue that chapter 10 should apply to this case. They argue that Skepnek waived the issue by not raising it at the trial court. They also argue that, because Raymark was not a necessary party to these lawsuits, the amended petition adding Raymark should be treated like a new lawsuit. They argue that no rational purpose is served by distinguishing whether the conduct is punishable based on whether Raymark was added to an existing suit or was sued separately. They rely on a case in which this Court held that a new venue statute did not apply to a necessary party added after the effective date of the statute. See Stanolind Oil & Gas Co. v. State, 153 S.W.2d 614, 616 (Tex. Civ. App.--Austin 1941, no writ). They reason that with non-necessary parties against whom severable claims are made, the reverse should be true and that the new statute should apply.

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