Miguel Angel Gonzalez Guilbot, Carlos A. Gonzalez Guilbot, and Maria Rosa Del Arena De Gonzalez v. Maria Del Carmen Guilbot Serros De Gonzalez

CourtCourt of Appeals of Texas
DecidedSeptember 30, 2008
Docket14-07-00047-CV
StatusPublished

This text of Miguel Angel Gonzalez Guilbot, Carlos A. Gonzalez Guilbot, and Maria Rosa Del Arena De Gonzalez v. Maria Del Carmen Guilbot Serros De Gonzalez (Miguel Angel Gonzalez Guilbot, Carlos A. Gonzalez Guilbot, and Maria Rosa Del Arena De Gonzalez v. Maria Del Carmen Guilbot Serros De Gonzalez) 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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Miguel Angel Gonzalez Guilbot, Carlos A. Gonzalez Guilbot, and Maria Rosa Del Arena De Gonzalez v. Maria Del Carmen Guilbot Serros De Gonzalez, (Tex. Ct. App. 2008).

Opinion

Reversed and Remanded and Opinion filed September 30, 2008

Reversed and Remanded and Opinion filed September 30, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00047-CV

MIGUEL ANGEL GONZALEZ GUILBOT, CARLOS A. GONZALEZ GUILBOT, AND MARIA ROSA DEL ARENA DE GONZALEZ, Appellants

V.

IN THE ESTATE OF MIGUEL ANGEL LUIS GONZALEZ Y VALLEJO, Appellee

On Appeal from the Probate Court No. 2

Harris County, Texas

Trial Court Cause No. 344,157-401

O P I N I O N


Appellants Miguel Angel Gonzalez Guilbot, Carlos A. Gonzalez Guilbot, and Maria Rosa del Arena de Gonzalez appeal from the trial court=s sanctions order and judgment awarding over $205 million in compensatory damages, punitive damages, and attorney=s fees against them to various parties, including appellee the Estate of Miguel Angel Luis Gonzales y Vallejo.  They argue that the sanctions order and judgment are void because (1) they were entered after appellants unsuccessfully removed the case to federal court but before the remand was complete, and thus the trial court had no jurisdiction, and (2) the sanctions order and judgment were entered while motions to recuse the relevant judges were pending.  We conclude that the trial court had jurisdiction because the remand was complete, but the sanctions order and judgment are nevertheless void because they were entered by judges with pending recusal motions.  Therefore, we reverse the sanctions order and judgment and remand for further proceedings.

                                I.  Factual and Procedural Background

This dispute centers around a large family enterprise and the litigation that ensued between family members after one of the co-founders of the business died.  The co-founder=s will was probated in 2003, and litigation began between the parties in 2004.

After several previous trial settings, in November 2006, Probate Judge Mike Wood set the case for trial on January 8, 2007.  About a week later, appellants removed the case to the United States District Court for the Southern District of Texas, Judge Lee Rosenthal=s court.  Within a month, Judge Rosenthal remanded the case and awarded attorney=s fees to appellee after concluding that appellants had no objectively reasonable basis for seeking removal.  See 28 U.S.C. ' 1447(c).  To expedite the case=s progress post-remand, Judge Rosenthal gave appellee=s counsel a certified copy of the remand order to hand deliver to the state court.  Despite the general rule prohibiting appeal of remand order, see id. ' 1447(d), appellants appealed the remand order to the Fifth Circuit Court of Appeals.


While the Fifth Circuit appeal was pending, appellants filed a motion to recuse Judge Wood.  Judge Wood refused to recuse himself and referred the motion to Judge Guy Herman, Presiding Judge, Statutory Probate Courts.  Judge Herman then assigned Probate Judge Gladys Burwell to hear the motion to recuse Judge Wood.  Appellants thereafter filed motions to recuse both Judge Herman and Judge Burwell.  Judge Herman set all three motions for hearing before himself.  Appellants did not appear at the hearing but instead sent a legal assistant to observe.  Judge Herman denied all the motions to recuse, including the motion to recuse himself, and assessed $12,000 in sanctions against appellants after finding the recusal motions were frivolous.

Judge Wood then held a bench trial and entered a final judgment, awarding judgment against appellants.  This appeal followed.

                                                      II.  Analysis

A.  Post-Removal Jurisdiction

In their second issue, appellants argue that the trial court did not have jurisdiction to enter a final judgment because the post-removal jurisdictional transfer back to state court has never been completed.

If a party follows the proper procedure for removing a case to federal court, the state court loses jurisdiction and may not proceed further unless the case is remanded.  See 28 U.S.C. ' 1446(d); In re Sw. Bell Tel. Co., 235 S.W.3d 619, 624 (Tex. 2007) (orig. proceeding).  If the federal court determines removal was improper and remands the case, A[a] certified copy of the order of remand shall be mailed by the clerk to the clerk of the State court.@  28 U.S.C. ' 1447(c).

After assessing attorney=s fees for a frivolous removal and issuing a remand order, Judge Rosenthal gave appellee=s counsel a copy of the remand order to hand deliver to the state court and thereby expedite the case, and this order was filed in the state court on December 15, 2006, the day after Judge Rosenthal signed the remand order.  Appellants argue that because the statute requires the clerk to mail a certified copy of the remand order to the state court, the hand delivery of the order did not complete the jurisdictionalal transfer.  Thus, according to appellants, the state court never regained jurisdiction, and any subsequent orders from the state court are void.  See Mapco, Inc. v. Forrest, 795 S.W.2d 700, 703 (Tex. 1990) (orig. proceeding) (holding that orders issued by a trial court without jurisdiction are void).


During the pendency of the present appeal, the Fifth Circuit issued its opinion in appellants= federal appeal and concluded that (1) appellants waived on appeal any argument that the remand procedure was defective because they never presented that issue to the district court and (2) in the alternative, it had no jurisdiction to consider a challenge to the clerk=s compliance with the relevant remand procedure.  See Gonzalez v. Guilbot, 255 Fed. Appx. 770, 771B72 (5th Cir. 2007).

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Miguel Angel Gonzalez Guilbot, Carlos A. Gonzalez Guilbot, and Maria Rosa Del Arena De Gonzalez v. Maria Del Carmen Guilbot Serros De Gonzalez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miguel-angel-gonzalez-guilbot-carlos-a-gonzalez-gu-texapp-2008.