Scott Bader, Inc., Amy C. Wright, Kern & Wooley, L.L.P., and National Pigments & Chemicals, Inc. v. Sandstone Products, Inc.

CourtCourt of Appeals of Texas
DecidedFebruary 28, 2008
Docket01-05-00940-CV
StatusPublished

This text of Scott Bader, Inc., Amy C. Wright, Kern & Wooley, L.L.P., and National Pigments & Chemicals, Inc. v. Sandstone Products, Inc. (Scott Bader, Inc., Amy C. Wright, Kern & Wooley, L.L.P., and National Pigments & Chemicals, Inc. v. Sandstone Products, Inc.) 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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Scott Bader, Inc., Amy C. Wright, Kern & Wooley, L.L.P., and National Pigments & Chemicals, Inc. v. Sandstone Products, Inc., (Tex. Ct. App. 2008).

Opinion

Opinion issued February 28, 2008




In The

Court of Appeals

For The

First District of Texas





NO. 01–05–00940–CV





SCOTT BADER, INC., AMY C. WRIGHT, KERN & WOOLEY, L.L.P., AND NATIONAL PIGMENTS & CHEMICALS, INC., Appellants


V.


SANDSTONE PRODUCTS, INC., Appellee





On Appeal from the 127th District Court

Harris County, Texas

Trial Court Cause No. 2000–27864A





* * *





NO. 01–06–00593–CV





SCOTT BADER, INC. AND NATIONAL PIGMENTS & CHEMICALS, INC., Appellants







Trial Court Cause No. 2000–27864





DISSENTING OPINION


          I respectfully dissent. I would hold that the sanctions assessed against Scott Bader were well within the discretion of the trial court and that there is no requirement that the trial court explain its rejection of lesser sanctions when, as here, the trial court’s order detailed the offending party’s abuses and directly tailored sanctions specifically authorized by Rule 215 of the Texas Rules of Civil Procedure to cure the prejudice to the innocent party caused by the abuse. I would affirm the judgment of the trial court.

The Test for Just Sanctions

          The Texas Supreme Court has set out a two-part test for determining whether sanctions are just and therefore within the discretion of the trial court. TransAmerican Natural Gas Corp. v. Powell, 811 S.W.2d 913, 917 (Tex. 1991). That test requires that there be “a direct relationship . . . between the offensive conduct and the sanction imposed,” i.e., that the sanction be “directed against the abuse and toward remedying the prejudice caused by the innocent party” and that the sanctions not be “excessive.” Id. at 917. In regard to the second prong, the court is required to consider the availability of less stringent sanctions and whether such lesser sanctions would fully provide compliance. Id. These standards set the bounds within which the trial court is to exercise its discretion to assess sanctions under Texas Rule of Civil Procedure 215 governing discovery abuse. Id. That test has been subsequently reaffirmed in Spohn Hospital v. Mayer, 104 S.W.3d 878, 882 (Tex. 2003) (citing TransAmerican, 811 S.W.2d at 917) and Cire v. Cummings, 134 S.W.3d 835, 839 (Tex. 2004).

The Trial Court’s Sanctions Order

          The trial court’s carefully articulated sanctions order in this case is set out in the majority opinion. That court made explicit findings that Scott Bader had “knowingly and in flagrant bad faith engaged in discovery abuse,” including (1) “withholding critical responsive documents until the production of more than 8,000 pages of documents on March 1, 2005, after the depositions in the lawsuit had already taken place”; (2) “producing documents in a manner calculated to conceal information (through removing the key first page of a document and marking out information in other documents), with conflicting and inadequate explanations for the same that lack credibility ”; (3) “presenting deposition witnesses with such critical documents and information concealed or not produced”; (4) “failing to name Terry Strickland as a witness with knowledge of relevant facts, or to produce responsive documents, related to Strickland’s role as director of Defendant SCOTT BADER, his role as the “main lead” in Defendant SCOTT BADER’s transition from using Co-Defendant Goodrich[’s] services to those of Co-Defendant Para-Chem, his direct supervision over specific issues regarding the formulation and testing of Defendant’s product, and his direct involvement in specific issues related to customer reports of problems”; (5) “failing to produce as a corporate representative a witness with knowledge as requested”; and (6) “filing two no-evidence motions for summary judgment on December 10, 2004 and February 23, 2005, respectively, when Defendant SCOTT BADER and its counsel knew that the production of documents and witnesses was deficient.

          The trial court found that Scott Bader’s “actions were calculated to conceal evidence that would indicate . . . that [its] product did not meet its stated specifications; and . . . that the stated specifications were modified.” It further found that Scott Bader’s actions “indicate a pattern or history of bad faith discovery abuse, demonstrate callous disregard for the responsibilities of discovery under the rules, and significantly interfere with the integrity and core judicial functions of this Court and its rulings.” For all of these reasons, the trial court found Scott Bader had prejudiced Sandstone’s ability to present its case, and it concluded that a sanctions order “directly related to the offensive conduct . . . is appropriate and necessary because a lesser sanction will not promote compliance.”

          The trial court sanctioned this behavior by requiring that the jury be instructed

“You are to presume (1) that the product that was shipped between mid-1999 and 2001 did not meet the specifications Scott Bader provided to Sandstone, and (2) that the specifications that Scott Bader provided to Sandstone for the product during mid-1999 and 2001 were modified.”


The trial court ordered that Scott Bader and its indemnitee, NPCI, were not permitted to rebut the factual presumptions set forth above, and it struck affirmative defenses addressed to the issue. The court also ruled that Scott Bader could not use Terry Strickland as a witness at trial and that Scott Bader “may not use the deposition testimony of any witness from a deposition unless SCOTT BADER first demonstrates to the Court that such deposition was taken after full production of documents.” The trial court then identified eight witnesses who were deposed before Scott Bader’s “production of critical documents on March 1, 2005.” Finally, the trial court ordered that Scott Bader pay $68,000 in sanctions for attorney’s fees and expenses incurred by Sandstone attributable to Scott Bader’s discovery abuse.

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Related

Cire v. Cummings
134 S.W.3d 835 (Texas Supreme Court, 2004)
Spohn Hospital v. Mayer
104 S.W.3d 878 (Texas Supreme Court, 2003)
TransAmerican Natural Gas Corp. v. Powell
811 S.W.2d 913 (Texas Supreme Court, 1991)

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Scott Bader, Inc., Amy C. Wright, Kern & Wooley, L.L.P., and National Pigments & Chemicals, Inc. v. Sandstone Products, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-bader-inc-amy-c-wright-kern-wooley-llp-and-n-texapp-2008.