Jose M. Lopez and Blanca Alvarez, Individually and as Next Friends of Vianca Lopez and Kassandra Lopez, Minors, and Eva Alvarez v. Juan Pablo Sandoval

CourtCourt of Appeals of Texas
DecidedFebruary 23, 2006
Docket13-03-00322-CV
StatusPublished

This text of Jose M. Lopez and Blanca Alvarez, Individually and as Next Friends of Vianca Lopez and Kassandra Lopez, Minors, and Eva Alvarez v. Juan Pablo Sandoval (Jose M. Lopez and Blanca Alvarez, Individually and as Next Friends of Vianca Lopez and Kassandra Lopez, Minors, and Eva Alvarez v. Juan Pablo Sandoval) 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.

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Jose M. Lopez and Blanca Alvarez, Individually and as Next Friends of Vianca Lopez and Kassandra Lopez, Minors, and Eva Alvarez v. Juan Pablo Sandoval, (Tex. Ct. App. 2006).

Opinion

                              NUMBER 13-03-322-CV

                         COURT OF APPEALS

                     THIRTEENTH DISTRICT OF TEXAS

                         CORPUS CHRISTI - EDINBURG

JOSE M. LOPEZ AND BLANCA

ALVAREZ, INDIVIDUALLY AND

AS NEXT FRIENDS OF VIANCA

LOPEZ AND KASSANDRA LOPEZ,

MINORS, AND EVA ALVAREZ,                                                Appellants,

                                                             v.

JUAN PABLO SANDOVAL,                                                              Appellee.

    On appeal from the 103rd District Court of Cameron County, Texas.

                               MEMORANDUM OPINION

          Before Chief Justice Valdez and Justices Yañez and Castillo

                            Memorandum Opinion by Justice Yañez


Appellants, Jose M. Lopez (ALopez@) and Blanca Alvarez, individually and as next friends of their minor children, Vianca and Kassandra Lopez, and Eva Alvarez (Blanca=s sister), sued appellee, Juan Pablo Sandoval, for injuries appellants allegedly sustained on March 22, 1998, when appellee=s vehicle Arear-ended@ the truck in which they were riding.  After the close of evidence presented to a jury, the trial court granted appellants a directed verdict on liability.  The only issue remaining for the jury was the amount of damages, if any, sustained by appellants.  The jury returned a verdict of zero damages and the trial court issued a take-nothing judgment against appellants.  By three issues, appellants contend (1) the trial court erred in denying their motion to disqualify Roerig, Oliveira & Fisher (Athe Roerig firm@), the law firm representing appellee, based on the firm=s prior representation of Lopez; (2) the trial court erred in allowing appellee=s counsel to impeach Lopez=s credibility by questioning him about the prior matter; and (3) the evidence is legally and factually insufficient to support the jury=s award of zero damages.  We affirm.

                                                   I.  DISQUALIFICATION ISSUE

In their first issue, appellants contend the trial court erred in denying their motion to disqualify appellee=s law firm, the Roerig firm, based on the firm=s prior representation of Lopez in a 1996 matter. 


During the cross-examination of Lopez, appellee=s counsel (an attorney with the Roerig firm) attempted to impeach Lopez by establishing his involvement in a 1996 accident, which he had failed to disclose in response to discovery requests.[1]  Following the cross-examination, it was revealed that the Roerig firm had represented Lopez as a defendant in a lawsuit arising out of the 1996 accident.  Appellants moved for a mistrial and to disqualify the Roerig firm from representing appellee in the present matter.  The trial court denied the motions.     

                                                         A.  Standard of Review

We review a trial court=s ruling on a motion to disqualify under an abuse of discretion standard.[2]  We will reverse the trial court's decision only where the trial court acted without reference to any guiding rules or principles, or acted in an arbitrary or unreasonable manner.[3]

                                                                Applicable Law

ADisqualification is a severe remedy.@[4]  AIt can result in immediate and palpable harm, disrupt trial court proceedings, and deprive a party of the right to have counsel of choice.@[5]  AIn considering a motion to disqualify, the trial court must strictly adhere to an exacting standard to discourage a party from using the motion as a dilatory trial tactic.@[6]


When contemplating whether disqualification of counsel is proper, the court must determine whether the matters embraced within the pending suit are substantially related

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Jose M. Lopez and Blanca Alvarez, Individually and as Next Friends of Vianca Lopez and Kassandra Lopez, Minors, and Eva Alvarez v. Juan Pablo Sandoval, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jose-m-lopez-and-blanca-alvarez-individually-and-a-texapp-2006.