Sharon Kay Keith v. Randall Dean Keith

Court of Appeals of Texas·Decided July 20, 2006·No. 01-04-01214-CV·Published

Opinion

Opinion issued July 20, 2006



In The

Court of Appeals

For The

First District of Texas





NO. 01-04-01214-CV





SHARON KAY KEITH, Appellant


V.


RANDALL DEAN KEITH, Appellee





On Appeal from the 312th District Court

Harris County, Texas

Trial Court Cause No. 2000-24422





DISSENTING OPINION

            I respectfully dissent. This case involves a non-frivolous Suit Affecting the Parent Child Relationship (SAPCR) that needed to be tried or mediated. It was not, and one of the litigants was hit with huge sanctions. I believe the trial court clearly abused its discretion in awarding sanctions against Sharon and that the opinion of this Court affirming the trial court’s judgment will have a chilling effect on the willingness of parents concerned for the safety of their children to approach the family courts. I would hold that (1) the sanctions order, even when read together with the trial court’s findings of fact and conclusions of law, fails to state the grounds for sanctions with particularity, as required for Rule 13 sanctions, and that (2) even if the judgment survived that hurdle, Randall failed to carry his burden of proving that Sharon’s suit was either groundless and brought in bad faith or groundless and harassing. I would reverse and render judgment for appellant.

Standard of Review

          The purpose of Rule 13 sanctions is to prevent pleading abuse. Monroe v. Grider, 884 S.W2d 811, 817 (Tex. App.—Dallas 1994, pet. denied); see also Home Owners Funding Corp. of America, 815 S.W.2d 884, 888 (Tex. App.—Corpus Christi 1991, no pet.). Rule 13 provides for sanctions if a party files a pleading that is either (1) groundless and brought in bad faith or (2) groundless and brought to harass. Tex. R. Civ. P. 13; see also Randolph v. Walker, L.L.P., 29 S.W.3d 271, 277 (Tex. App.—Houston [14th Dist.] 2000, pet. denied). A suit is groundless for purposes of Rule 13 if it has “no basis in law or fact and [is] not warranted by good faith argument for the extension, modification, or reversal of existing law.” Elkins v. Stotts-Brown, 103 S.W.3d 664, 668 (Tex. App.—Dallas 2003, no pet.) (quoting Tex. R. Civ. P. 13). “Bad faith is not simply bad judgment or negligence, but means the conscious doing of a wrong for dishonest, discriminatory, or malicious purpose.” Id. at 669; Mattly v. Spiegel, Inc., 19 S.W.3d 890, 896 (Tex. App.—Houston [14th Dist.] 2000, no pet.) (quoting Falk & Mayfield L.L.P. v. Molzan, 974 S.W.2d 821, 828 (Tex. App.—Houston [14th Dist.] 1998, pet. denied)). “Harassment” is used “to describe words, gestures, and actions that tend to annoy, alarm, and verbally abuse another person.” Elkins, 103 S.W.3d at 669. If a pleading is filed in violation of Rule 13, “the court, upon motion or upon its own initiative, after notice and hearing, shall impose an appropriate sanction available under Rule [of Civil Procedure] 215.2(b), upon the person who signed it, a represented party, or both.” Tex. R. Civ. P. 13. No sanctions may be imposed under Rule 13 “except for good cause, the particulars of which must be stated in the sanctions order.” Id.

          To establish a right to sanctions under Texas Rule of Civil Procedure 13, a party must first overcome the presumption that the pleadings are filed in good faith; that is, he must prove that the filing is “the conscious doing of a wrong for dishonest,

discriminatory, or malicious purposes.” See Elkins, 103 S.W.3d at 668–69; Mattly, 19 S.W.3d at 896; Monroe, 884 S.W.2d at 819. He must then plead and prove that the contentions in the pleading are groundless, i.e., without any “basis in law or fact and not warranted by good faith argument for the extension, modification, or reversal of existing law.” Tex. R. Civ. P. 13.

          To determine whether rule 13 sanctions are proper, the trial court must examine the circumstances existing at the time the party filed the pleading. Elkins, 103 S.W.3d at 668; Monroe, 884 S.W.2d at 817. Thus “it [is] imperative for the trial court to convene and conduct an evidentiary hearing.’” Randolph, 29 S.W.3d at 277 (quoting Karagounis v. Property Co. of America, 970 S.W.2d 761, 765 (Tex. App.—Amarillo 1998, pet. denied)). To sanction a party for filing a groundless pleading, the trial court has to find, based on facts in the record, that the party was on notice that the facts upon which the pleading was based were incorrect and that he, nevertheless, filed the pleading without making a reasonable inquiry into the facts. See Bradt, 14 S.W.3d at 763; Monroe, 884 S.W.2d at 819. “Reasonable inquiry means the amount of examination that is reasonable under the circumstances of the case.” Mattly, 19 S.W.3d at 897 (quoting Monroe, 884 S.W.2d at 817).

          No rule 13 sanctions may be imposed “except for good cause, the particulars of which must be stated in the sanctions order.” Tex. R. Civ. P. 13; Alpert, 178 S.W.3d at 411; Gorman v. Gorman, 966 S.W.2d 858, 867 (Tex. App.—Houston [1st Dist.] 1998, pet. denied); Woodward v. Jaster, 933 S.W.2d 777, 782 (Tex. App.—Austin 1996, no pet.); Kahn v. Garcia, 816 S.W.2d 131, 133 (Tex. App.—Houston [1st Dist.] 1991, no writ) (“Rule 13 imposes a duty on the trial court to point out with particularity the acts or omissions on which sanctions are based.”). However, “a trial court’s failure to make particular findings in a rule 13 order may constitute harmless error when the trial court’s findings of fact and conclusions of law supply the particulars of good cause required by rule 13.” Gorman, 966 S.W.2d at 867.

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