Phennel v. Roach

789 S.W.2d 612, 1990 Tex. App. LEXIS 1467, 1990 WL 84252
CourtCourt of Appeals of Texas
DecidedMarch 21, 1990
Docket05-89-00762-CV
StatusPublished
Cited by22 cases

This text of 789 S.W.2d 612 (Phennel v. Roach) 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
Phennel v. Roach, 789 S.W.2d 612, 1990 Tex. App. LEXIS 1467, 1990 WL 84252 (Tex. Ct. App. 1990).

Opinions

HOWELL, Justice,

dissenting.

I dissent. This case, insofar as Carrier is concerned, is controlled by Cox v. Realty Development Corp., 748 S.W.2d 492 (Tex.App.—Dallas 1988, no writ). The majority has not distinguished Cox, which is directly on point, and which holds that sanctions imposed for discovery abuse by one party cannot be imposed against another party committing no discovery abuse. Furthermore, the trial court abused its discretion in dismissing Worker’s suit on the basis of his original attorney’s omission. The entire case should be reversed and remanded.

CARRIER’S CAUSE OF ACTION

The issue has already been decided previously by this court. Cox held that once an insurance carrier has paid a claim and as a result is subrogated to the rights of its insured against a third party, the carrier becomes a pro tanto owner of the insured’s cause of action. Therefore, we held that it was an abuse of discretion for the trial court to dismiss the carrier’s cause of action because of the insured’s discovery violations. Cox, 748 S.W.2d at 494. Atrial court cannot dismiss a party’s case without [616]*616sanctionable misconduct on the part of that party. Id.

It is to be noted that the majority has cited only worker’s compensation cases in support of its ruling against Carrier — no discovery/sanction cases. Possibly, the majority has some notion that Carrier’s case is subject to a different rule because its subrogation rights are regulated by the Worker’s Compensation Act. Any such holding would be a distinction without a difference.

Just as provided by decisions under the Act, including our majority’s citations, it is a well recognized principle of decisional law that a subrogee possesses but a derivative cause of action. See Fox v. Kroeger, 119 Tex. 511, 517, 35 S.W.2d 679, 681 (1931) (subrogee “stands in the shoes” of his sub-rogor). A subrogee can rise no higher than his source: he can assert no right greater than his subrogor; Platte v. Securities Inv. Co., 55 S.W.2d 551, 553 (Tex.Comm’n App.1932, judgm’t adopted); Anchor Casualty Co. v. Robertson Transport Co., 389 S.W.2d 135, 139 (Tex.Civ.App.-Corpus Christi 1965, writ ref’d n.r.e.); he is subject to all defenses that could have been asserted against his subrogor, Platte, 55 S.W.2d at 553; see Hicks v. Wright, 564 S.W.2d 785, 797-98 (Tex.Civ.App.-Tyler 1978, writ ref’d n.r.e.).

Likewise, it is also a well established principle of the general law that a partial assignment or partial subrogation of a claim does not create a separate and independent cause of action. Traders & General Ins. Co. v. Richardson, 387 S.W.2d 478, 479 (Tex.Civ.App.-Beaumont 1965, writ ref’d) (insurer paid insured for property damage; insured sued third-party tort-feasor for personal injuries, but settled, and agreed judgment was entered; payment of money by insurer did not split insurer’s cause of action; thus, judgment in insured’s suit was a bar in insurer’s suit against third-party). Again, that principle has no application to the problem before us: May a trial court dismiss the action of a separately represented subrogee worker’s compensation insurance carrier on account of the failure of the worker and his attorney, if any, to properly respond to discovery? Cox requires a negative answer.

As a matter of fact, the inevitable conclusion to be reached from the majority’s reasoning is that, following the dismissal of Worker’s action, our trial court had no power except to dismiss Carrier’s action. Our majority necessarily holds that a carrier’s cause of action automatically perishes when a worker’s cause of action perishes— that our trial court was possessed of no other possible recourse after dismissing Worker’s action. Such conclusion is not in harmony with the Act; rather, it is out of harmony with the provision of the Act allowing Carrier to independently bring suit in the name of Worker to protect its subro-gation rights. Tex.Rev.Civ.Stat.Ann. art. 8307, § 6a (Vernon Supp.1989). It is clear from the statute that had Worker failed or refused to institute suit, Carrier could have done so. Is a carrier in any less position when the worker does bring suit and the carrier intervenes? There is no reason to so hold. Assume for a moment that having filed suit, and Carrier having intervened, as did happen here, Worker’s attorney concluded that he could more profitably expend his time on other matters than upon the response to third party defendant’s discovery, as perhaps he did. Assume however, that instead of withdrawing, counsel non-suited Worker’s action. If our majority be correct, the only logical conclusion would be that the same fate must befall Carrier’s subrogation action; it also had to be non-suited. However, any such result would fly in the face of the statutory provision expressly allowing Carrier to independently prosecute an action in Worker’s name. Likewise any ruling that a carrier’s action for subrogation is necessarily and automatically forfeited whenever a worker’s action is dismissed as a discovery sanction, also flies in the face of the statutory provision allowing a carrier to proceed independently when the worker fails or refuses to do so.

On analysis, such is exactly what happened in the case at hand. Through his original attorney, Worker timely filed his lawsuit. However, Worker, through his [617]*617original attorney, failed to prosecute his lawsuit with reasonable diligence. Such a holding by the trial court was the essence of the dismissal order. The statute expressly protects Carrier from any omission of Worker in failing to diligently bring suit. By implication, it protects Carrier from any omission of Worker in failing to diligently prosecute the action.

However, the foregoing discussion really misses the mark. The ultimate ground for refusing to sanction the dismissal of Carrier’s action is the fact that we are dealing with punishment. It is fundamental, almost trite, to point out that punishment is for the guilty, not the innocent. The trial Court found no sanctionable conduct on behalf of Carrier. Without a basis for punishment, it was without authority to punish. See Bodnow Corp. v. City of Hondo, 721 S.W.2d 839, 840 (Tex.1986) (trial court abused its discretion when it made party liable for discovery expenses caused by misconduct of another). The rules relating to discovery sanctions must be flexible; the trial courts must be free to apply the proper sanctions where they are merited. On the other hand, the law relating to sanctions must be free from the type of mechanical approach manifested by our majority where the shortcomings of one litigant are attributed to another. Every party to litigation who engages in discovery violations must be held fully answerable for his own misconduct but never for the misconduct of others where he bears no fault. The sanctions against Carrier must be reversed.

WORKER’S CAUSE OF ACTION

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

Related

Prudential Property & Casualty Co. v. Dow Chevrolet-Olds, Inc.
10 S.W.3d 97 (Court of Appeals of Texas, 1999)
Herrera v. Wembley Investment Company
12 S.W.3d 83 (Court of Appeals of Texas, 1998)
Texas Workers' Compensation Insurance Fund v. Serrano
962 S.W.2d 536 (Texas Supreme Court, 1998)
Houston General Insurance Co. v. Campbell
964 S.W.2d 691 (Court of Appeals of Texas, 1998)
In Re Romero
956 S.W.2d 659 (Court of Appeals of Texas, 1997)
Autry v. Dearman
933 S.W.2d 182 (Court of Appeals of Texas, 1996)
Hartford Casualty Insurance Co. v. Albertsons Grocery Stores
931 S.W.2d 729 (Court of Appeals of Texas, 1996)
Smith v. Babcock & Wilcox Const. Co., Inc.
915 S.W.2d 22 (Court of Appeals of Texas, 1996)
Franks v. Sematech, Inc.
938 S.W.2d 462 (Court of Appeals of Texas, 1995)
Guillot v. Hix
838 S.W.2d 230 (Texas Supreme Court, 1992)
MacArangal v. Andrews
838 S.W.2d 632 (Court of Appeals of Texas, 1992)
Dempsey v. Pfizer, Inc.
813 S.W.2d 205 (Court of Appeals of Texas, 1991)
Phennel v. Roach
789 S.W.2d 612 (Court of Appeals of Texas, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
789 S.W.2d 612, 1990 Tex. App. LEXIS 1467, 1990 WL 84252, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phennel-v-roach-texapp-1990.