Marilyn McKeithan v. Bradford Condit

CourtCourt of Appeals of Texas
DecidedNovember 29, 2018
Docket13-16-00348-CV
StatusPublished

This text of Marilyn McKeithan v. Bradford Condit (Marilyn McKeithan v. Bradford Condit) 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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Marilyn McKeithan v. Bradford Condit, (Tex. Ct. App. 2018).

Opinion

NUMBER 13-16-00348-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI - EDINBURG

MARILYN MCKEITHAN, Appellant,

v.

BRADFORD CONDIT, Appellee.

On appeal from the 117th District Court of Nueces County, Texas.

MEMORANDUM OPINION Before Chief Justice Valdez and Justices Contreras and Hinojosa Memorandum Opinion by Chief Justice Valdez

Appellant Marilyn McKeithan appeals the trial court’s declaratory judgment in favor

of appellee Bradford Condit. By five issues, McKeithan contends that (1) the trial court

improperly entered death penalty sanctions before attempting to impose lesser sanctions,

(2) the trial court previously determined that the property at issue is McKeithan’s

homestead, (3) federal courts have already determined that the property at issue is McKeithan’s homestead, (4) the trial court erred by allowing Condit to re-litigate the issue

of whether the property constituted McKeithan’s homestead, and (5) the trial court erred

in not conditioning the award of appellate attorney’s fees. We reverse and remand.

I. BACKGROUND

According to McKeithan, in 2009, Condit, a Texas attorney, sued McKeithan, his

former client, for breach of contract and fraud. McKeithan filed a counterclaim alleging

breach of fiduciary duty and common law fraud. McKeithan failed to appear at the trial

on the merits, and Condit prevailed on his causes of action for breach of contract and

fraud, and the trial court granted a directed verdict in favor of Condit on McKeithan’s

counterclaims. The trial court awarded Condit $83,999. On appeal to this Court, we

reversed the trial court’s judgment for fraud and attorney’s fees, and we remanded for a

new trial. 1 McKeithan v. Condit, No. 13-10-00226-CV, 2013 WL 6729963, at *3 (Tex.

App.—Corpus Christi Dec. 19, 2013, no pet.) (mem. op.) (remanding for new trial because

the evidence was insufficient to support the post-answer default judgment).

Prior to our remand in McKeithan, 2013 WL 6729963, at *3, Condit added his claim

for a declaration that McKeithan’s real property is not her homestead in a pleading

entitled, “Plaintiff’s Post-Judgment Motion to Determine Real Property Status” filed on

July 21, 2010. The trial court severed Condit’s other claims from the declaratory judgment

action and the latter forms the basis of this appeal. In the declaratory judgment cause,

Condit filed a motion for sanctions against McKeithan due to her alleged discovery

abuses. The trial court granted Condit’s motion for sanctions, struck McKeithan’s

1 We affirmed the judgment regarding the breach of contract claim.

2 pleadings, and at the bench trial, disallowed McKeithan from testifying or offering

evidence that the property at issue is her homestead.

Following the trial, the trial court ruled in favor of Condit, determining that the

property is not McKeithan’s homestead. The trial court awarded Condit attorney’s fees

for “preparation of trial of this matter” in the amount of $8,000, $15,000 for an appeal,

$10,000 if a petition for review were filed, and an additional $15,000 if the Texas Supreme

Court ordered briefing. McKeithan filed a motion for new trial and request for issuance of

stay. The trial court held a hearing on McKeithan’s motion for new trial on June 28, 2016.

After considering the parties’ arguments and briefing, the trial court denied McKeithan’s

motion for new trial. This appeal followed.

II. DEATH PENALTY SANCTIONS

By her first issue, McKeithan contends that the trial court erred by imposing death

penalty sanctions because it did not attempt to impose lesser sanctions, the sanctions

imposed were not proportional, and the sanctions were excessive. Condit responds that

the trial court followed the law, and therefore, it could not have abused its discretion.

Specifically, Condit argues that the sole remedy for not timely supplementing discovery

is exclusion of evidence, which the trial court did in this case when McKeithan “completely

disregarded the duty to follow [the trial] court’s discovery and disclosure requirement rules

12 times between 2009 and 2016, including failing to attend four depositions two of which

were court ordered, and after having had four bankruptcy cases dismissed for either

failing to disclose her assets or lying multiple times about them.”

A. Applicable Law and Standard of Review

3 Sanctions for discovery abuse serve three legitimate purposes: (1) to secure

compliance with the discovery rules; (2) to deter other litigants from similar misconduct;

and (3) to punish violators. Chrysler Corp. v. Blackmon, 841 S.W.2d 844, 849 (Tex.

1992). When a party fails to comply with proper discovery requests or fails to obey an

order to provide or permit discovery, the trial court may, after notice and hearing, make

such orders in regard to the failure, which includes, among other things, an order striking

out pleadings, dismissing with or without prejudice the action or proceedings, or rendering

a default judgment against the disobedient party. TEX. R. CIV. P. 215.2. Although

punishment, deterrence, and securing compliance continue to be valid reasons for

imposing sanctions, these considerations alone will not justify “trial by sanctions.”

Chrysler Corp., 841 S.W.2d at 849; Westfall Family Farms, Inc. v. King Ranch, Inc., 852

S.W.2d 587, 591 (Tex. App.—Dallas 1993, writ denied).

Notwithstanding rule 215, discovery abuse sanctions must be “just.” Chrysler

Corp., 841 S.W.2d at 849; TransAm. Nat. Gas Corp. v. Powell, 811 S.W.2d 913, 917

(Tex. 1991) (orig. proceeding). Moreover, so called death penalty sanctions are limited

by constitutional due process. 2 TransAm. Nat. Gas Corp., 811 S.W.2d at 917. Thus, “a

death penalty sanction cannot be used to adjudicate the merits of claims or defenses

unless the offending party’s conduct during discovery justifies a presumption that its

claims or defenses lack merit.” Paradigm Oil, Inc. v. Retamco Operating, Inc., 372 S.W.3d

177, 184 (Tex. 2012).

2Death penalty sanctions include striking the pleadings, dismissing the case, rendering default judgment against the disobedient party, or in some cases excluding essential evidence. In re M.J.M., 406 S.W.3d 292, 297 (Tex. App.—San Antonio 2013, no pet.). Condit does not dispute that the trial court issued death penalty sanctions in this case.

4 Absent a party’s flagrant bad faith or counsel’s callous disregard for the

responsibilities of discovery under the rules, sanctions that prevent a decision on the

merits of a case cannot be justified. Chrysler Corp., 841 S.W.2d at 849; TransAm., 811

S.W.2d at 918. However, even in those cases where death penalty sanctions can be

justified, a trial court must first consider less stringent sanctions and if those lesser

sanctions would adequately promote compliance, deterrence, and punishment. Chrysler

Corp., 841 S.W.2d at 849; TransAm., 811 S.W.2d at 917. In all but the most exceptional

cases, before the trial court may strike a party’s pleadings, the record must show that the

trial court considered and tested less stringent sanctions. Cire v. Cummings, 134 S.W.3d

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