Tom Reed and Jared Woodfill v. the Methodist Hospital D/B/A the Methodist Hospital System, and the Medical Staff of Houston Methodist the Woodlands Hospital

CourtCourt of Appeals of Texas
DecidedMay 1, 2025
Docket09-23-00259-CV
StatusPublished

This text of Tom Reed and Jared Woodfill v. the Methodist Hospital D/B/A the Methodist Hospital System, and the Medical Staff of Houston Methodist the Woodlands Hospital (Tom Reed and Jared Woodfill v. the Methodist Hospital D/B/A the Methodist Hospital System, and the Medical Staff of Houston Methodist the Woodlands Hospital) 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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Tom Reed and Jared Woodfill v. the Methodist Hospital D/B/A the Methodist Hospital System, and the Medical Staff of Houston Methodist the Woodlands Hospital, (Tex. Ct. App. 2025).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-23-00259-CV __________________

TOM REED AND JARED WOODFILL, Appellants

V.

THE METHODIST HOSPITAL D/B/A THE METHODIST HOSPITAL SYSTEM, AND THE MEDICAL STAFF OF HOUSTON METHODIST THE WOODLANDS HOSPITAL, Appellees

__________________________________________________________________

On Appeal from the 284th District Court Montgomery County, Texas Trial Cause No. 23-01-01246-CV __________________________________________________________________

MEMORANDUM OPINION

Tom Reed (“Reed” or “Plaintiff”) and Jared Woodfill (“Woodfill”) appeal

from an order awarding Appellees The Methodist Hospital d/b/a The Methodist

Hospital System, and The Medical Staff of Houston Methodist The Woodlands

Hospital (“the Hospital” or “Appellees”) attorney’s fees as sanctions on Woodfill.

We affirm.

1 Procedural History

Tom Reed, a physician (D.P.M.), filed an Original Petition against the

Hospital in Harris County in June of 2022 alleging wrongful termination. The case

was later transferred to Montgomery County, pursuant to the Hospital’s Motion to

Transfer Venue.

In April of 2023, the Hospital filed a Motion to Compel Discovery, alleging

that Plaintiff has failed to verify responses, failed to answer interrogatories, and

failed to provide responses to requests for production. According to the Motion,

Plaintiff originally brought claims in September of 2021 against the Hospital in

Montgomery County in Cause No. 21-09-12645, and after Plaintiff did not respond

to the Hospital’s discovery requests, the trial court granted Plaintiff’s nonsuit.

Thereafter, Plaintiff filed a second suit against the Hospital making the same claims

in Harris County, and the case was transferred to Montgomery County as Cause No.

23-01-01246.

In its Motion to Compel Discovery the Hospital alleged that its discovery

requests were “substantively identical to those served in April 2022 in the 1st

Montgomery County Suit.” According to the motion, after having been granted

multiple extensions to respond to discovery requests, Plaintiff served his responses

on March 20, 2023, but they were “overall deficient [] and contained incomplete

answers and groundless objections.” The Hospital further alleged that Plaintiff

2 produced no documents in response to the Hospital’s requests for production. After

counsel for the parties conferred, Plaintiff served some additional documents, but

the Hospital maintained the responses were inadequate and did not correct the

original deficiencies. The Hospital asked the trial court to compel Plaintiff to provide

proper responses to its written discovery requests because “Plaintiff’s counsel has

not responded to the [Hospital’s] April 13, 2023 letter with the requested responses

or items.” The trial court granted the motion on May 1, 2023, ordering Plaintiff to

provide full and complete responses and documents within seven days of the court’s

order.

On May 30, 2023, the Hospital filed its Motion to Enforce Court Order and

Show Cause pursuant to Texas Rule of Civil Procedure 215.2. Therein, the Hospital

alleged that Plaintiff had not even attempted to comply with the trial court’s May 1,

2023 Order on Defendant’s Motion to Compel Discovery. The Motion to Enforce

outlined the Hospital’s efforts to work with Plaintiff so the Plaintiff could correct

deficient responses to discovery requests from February through May of 2023, and

alleged that “Plaintiff has provided no amended and/or supplemental responses to

any of the Court ordered discovery requests.” The Hospital asked the trial court to

“issue a show cause order for Plaintiff Tom Reed, D.P.M. and Plaintiff’s counsel,

and that upon hearing they be held in contempt and sanctioned as requested[]” and

3 that the trial court award the Hospital attorney’s fees and costs related thereto. A

show-cause hearing was noticed on the motion for June 16, 2023.

Show-Cause Hearing

The trial court held a show-cause hearing on June 16, 2023. Neither Tom Reed

(Plaintiff) nor his attorney (Jared Woodfill) appeared. The trial court made a record

notation that two people, including Woodfill, at the Woodfill Law Firm were served

with notice of the hearing. Counsel for the Hospital told the trial court that Woodfill

had not responded to discovery requests since the trial court signed its May 1st order.

Counsel for the Hospital also told the trial court that they had observed a pattern in

Woodfill’s practice to not respond to dispositive motions and later file a motion for

new trial claiming there were other pressing matters. More specifically, counsel for

the Hospital informed the trial court that Woodfill had nonsuited the cause originally

filed in Harris County “to avoid the discovery[.]” The Hospital’s counsel also told

the trial court that in other cases in Montgomery County, they had served numerous

sets of discovery, and after giving numerous extensions to respond, Woodfill non-

suited the cases and refiled in Harris County, and the Hospital’s attorney gave the

trial court a copy of three documents from some of the cases as examples but none

of those documents appear in the record.

The following exchange occurred between the trial court and the Hospital’s

attorney:

4 [The Court]: Mr. Woodfill has filed no response to your motion and has opted not to appear here today though he was notified to come. It suggests very strongly to me that [the Hospital] is in a very bad position in trying to litigate this case with a plaintiff who is not participating in anything. It is my review of this file that Mr. Woodfill has literally filed nothing since the transfer came over from Harris County in January of 2023. It feels that he does not wish to participate. So my inclination is to order him to appear and show cause why he should not be forced to comply with the Court’s order on civil contempt, slash, why he should not be punished for putting you-all in this position, either through an award of attorneys’ fees, a criminal fine[,] or time in the Montgomery County Jail. I’m not inclined to issue that punishment on his client. I think that the evidence that you’ve presented me makes it very clear that this is an attorney-driven nonparticipation, but if you have reason to believe that Tom Reed, D.P.M., is somehow responsible for any of the nonresponsiveness that you’ve experienced, I’ll hear about it.

[Counsel for the Hospital]: I don’t think so, Your Honor. . . .

[The Court]: Okay. So my inclination is not to do a show-cause order as it pertains to our plaintiff but instead only as to his attorney. . . . It is altogether unusual to have someone completely ignore both a set of discovery requests and a court order requiring a response.

After the hearing concluded, the trial court signed a Show Cause Order. The

trial court found there was sufficient cause to conclude that Jared Woodfill had

violated the Order Granting Defendants’ Motion to Compel Discovery and “cause

to believe that Plaintiff, through his counsel, Jared Woodfill, is in contempt of this

Court’s Order[.]” The order required Woodfill to appear for a Show Cause Hearing

on July 14, 2023, and explained that, if Woodfill was found in contempt at the July

hearing, then the trial court may sentence him to up to 180 days in the Montgomery

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Tom Reed and Jared Woodfill v. the Methodist Hospital D/B/A the Methodist Hospital System, and the Medical Staff of Houston Methodist the Woodlands Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tom-reed-and-jared-woodfill-v-the-methodist-hospital-dba-the-methodist-texapp-2025.