San Benito Consolidated Independent School District v. McGinnis, Lochridge & Kilgore, L.L.P. And William H. Bingham, Individually and in His Capacity as Partner and Agent of McGinnis, Lochridge & Kilgore, L.L.P.

CourtCourt of Appeals of Texas
DecidedAugust 14, 1997
Docket03-96-00643-CV
StatusPublished

This text of San Benito Consolidated Independent School District v. McGinnis, Lochridge & Kilgore, L.L.P. And William H. Bingham, Individually and in His Capacity as Partner and Agent of McGinnis, Lochridge & Kilgore, L.L.P. (San Benito Consolidated Independent School District v. McGinnis, Lochridge & Kilgore, L.L.P. And William H. Bingham, Individually and in His Capacity as Partner and Agent of McGinnis, Lochridge & Kilgore, L.L.P.) 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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San Benito Consolidated Independent School District v. McGinnis, Lochridge & Kilgore, L.L.P. And William H. Bingham, Individually and in His Capacity as Partner and Agent of McGinnis, Lochridge & Kilgore, L.L.P., (Tex. Ct. App. 1997).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-96-00643-CV

San Benito Consolidated Independent School District, Appellant


v.



McGinnis, Lochridge & Kilgore, L.L.P.; and William H. Bingham,

Individually and in his Capacity as Partner and Agent of

McGinnis, Lochridge & Kilgore, L.L.P., Appellees



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 345TH JUDICIAL DISTRICT

NO. 95-14336, HONORABLE SCOTT McCOWN, JUDGE PRESIDING

San Benito Consolidated Independent School District (the "District"), appellant, brought suit against McGinnis, Lochridge & Kilgore, L.L.P. and attorney William H. Bingham (collectively the "Law Firm"), appellees, alleging legal malpractice in failing to file, on the District's behalf, a suit for judicial review of an order issued by the Commissioner of Education. The trial court granted the Law Firm's motion for summary judgment. On appeal, the District contends in three points of error that the trial court erroneously applied the substantial evidence rule and that the evidence raises a fact issue as to the existence of an attorney-client relationship. The District also argues that the Commissioner's decision is not supported by substantial evidence. We will affirm.
FACTUAL AND PROCEDURAL BACKGROUND

On February 11, 1994, the Texas Commissioner of Education, Lionel R. Meno, issued a decision approving the detachment of 320.949 acres of land from the District and the attachment of the tract to the Harlingen Consolidated Independent School District. The District asserts that it engaged the Law Firm to prepare and file in Travis County district court a suit for judicial review of the Commissioner's order pursuant to Act of June 6, 1990, 71st Leg., 6th C.S., ch. 1, sec. 2.22, 1990 Tex. Gen. Laws 1, 22 (Tex. Educ. Code Ann. § 11.13(c), since repealed and recodified at Tex. Educ. Code Ann. § 7.057(d) (West 1996)) (hereinafter "former section 11.13(c)"). The Law Firm did not file the suit within the applicable time limit, and the District was left without a remedy. The District sued the Law Firm alleging negligence, breach of contract, and violations of the Deceptive Trade Practices Act, Tex. Bus. & Com. Code Ann. §§ 17.46-.63 (West 1987 & Supp. 1997).

The Law Firm filed a motion for summary judgment alleging there was no evidence of an attorney-client relationship. In the alternative, the Law Firm argued that even if a breach of duty had occurred, it did not cause the District any harm because the Commissioner's ruling was supported by substantial evidence and, therefore, the District would not have succeeded in its suit for judicial review. See Millhouse v. Wiesenthal, 775 S.W.2d 626, 627 (Tex. 1989) (to prove proximate cause in legal malpractice action, client must show underlying lawsuit would have been successful "but for" attorney's negligence). The trial court granted the Law Firm's motion for summary judgment by general order, (1) and this appeal followed.



DISCUSSION

To obtain summary judgment, a movant must show there is no genuine issue of material fact and that it is entitled to judgment as a matter of law. Nixon v. Mr. Property Management Co., 690 S.W.2d 546, 548-49 (Tex. 1985). In deciding whether there is a disputed material fact issue precluding summary judgment, the trial court must take evidence favorable to the nonmovant as true. Id. Furthermore, the court must indulge every reasonable inference in favor of the nonmovant and resolve any doubts in the nonmovant's favor. Id.

When a defendant seeks to obtain summary judgment based on a plaintiff's inability to prove its case, the defendant must conclusively disprove at least one element of each of the plaintiff's causes of action. Lear Siegler, Inc. v. Perez, 819 S.W.2d 470, 471 (Tex. 1991). Only after a defendant conclusively disproves an essential element of the plaintiff's cause of action does the plaintiff shoulder the burden of producing controverting evidence and raising a fact issue as to the negated element. See City of Houston v. Clear Creek Basin Auth., 589 S.W.2d 671, 678 (Tex. 1979). When a summary judgment order does not state the specific basis for the court's decision, we must uphold the order if any of the theories advanced in the motion for summary judgment were meritorious. Rogers v. Ricane Enters., Inc., 772 S.W.2d 76, 79 (Tex. 1989).

In its first point of error, the District contends the trial court erroneously applied a "pure substantial evidence" review in determining whether the District could have succeeded in its appeal of the Commissioner's decision. The District argues that former section 11.13(c), the statute that gave the District the right to seek judicial review of the Commissioner's ruling, provided for "substantial evidence de novo" review. Substantial-evidence-de-novo review allows new evidence to be presented to the reviewing body, here the district court. (2) Thus, the District argues the trial court could not determine as a matter of law that the District would not have succeeded in its judicial challenge to the Commissioner's decision, because the reviewing district court would not have been limited to the administrative record in its review of the Commissioner's decision, and evidence not submitted to the Commissioner could have been presented to the court. See Wylie Indep. Sch. Dist. v. Central Educ. Agency, 488 S.W.2d 166, 168 (Tex. Civ. App.--Austin 1972, writ ref'd n.r.e.).

A proceeding of this nature before the Commissioner of Education is a "contested case." See Tex. Gov't Code Ann. § 2001.003(1), (7) (West Supp. 1997). A suit for judicial review of the Commissioner's decision is therefore governed by the Administrative Procedure Act ("APA"), Tex. Gov't Code Ann. § 2001.003(1) (West Supp. 1997). Under the APA, there are only two standards of review: "pure substantial evidence" and "pure trial de novo." See Tex. Gov't Code Ann. §§ 2001.173-.174 (West Supp. 1997). Accordingly, we reject the District's contention that substantial evidence de novo is the proper standard for judicial review.

That does not end our inquiry, however. Under a pure-trial-de-novo review, the decision of the lower agency or board is automatically vacated upon the taking of an appeal, and the reviewing tribunal not only hears new evidence, but also substitutes its discretion and judgment for that of the lower body. This type of review is technically not an "appeal" at all, but a new proceeding. See Central Educ. Agency v.

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San Benito Consolidated Independent School District v. McGinnis, Lochridge & Kilgore, L.L.P. And William H. Bingham, Individually and in His Capacity as Partner and Agent of McGinnis, Lochridge & Kilgore, L.L.P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/san-benito-consolidated-independent-school-district-v-mcginnis-lochridge-texapp-1997.