Victoria Hall, Holli Roffey, John C. Osborne, and the Law Offices of John C. Osborne, P.L.L.C. v. Roxane Guest and Leslie Weldy

Court of Appeals of Texas·Decided February 5, 2009·No. 09-08-00041-CV·Published

Opinion

In The



Court of Appeals



Ninth District of Texas at Beaumont



____________________



NO. 09-08-00041-CV



VICTORIA HALL, HOLLI ROFFEY, JOHN C. OSBORNE, AND

THE LAW OFFICES OF JOHN C. OSBORNE, P.L.L.C., Appellants



V.



ROXANE GUEST AND LESLIE WELDY, Appellees



On Appeal from the 221st District Court

Montgomery County, Texas

Trial Cause No. 07-01-00732 CV



MEMORANDUM OPINION

This is an appeal from an order awarding monetary sanctions. We affirm.

I. Background

Victoria Hall and Holli Roffey filed this lawsuit after the North Country Women's Tennis League ("NCWTL" or "League") suspended them for their conduct during a doubles match. Hall and Roffey forfeited the match to the opposing team, Roxane Guest (1) and Leslie Weldy. After the match ended, Hall and Roffey "were upset and hit a couple of tennis balls into the fence around the court." Peggy Payne and Kay Rice, the supervisors of the Guest-Weldy team, filed charges with the NCWTL and accused Hall and Roffey of intentionally trying to hit Guest and Weldy with the tennis balls. After the League concluded its investigation, it suspended Hall and Roffey for eight months, and placed Guest on probation for her role in the events that occurred prior to Hall and Roffey's decision to forfeit the match.

Subsequently, Hall and Roffey sued Guest, Weldy, Payne, and Rice for defamation per se. Hall and Roffey asserted that the defendants had falsely accused them of "unsportsmanlike conduct," and lodged "disparaging and untrue accusations with the NCWTL." Approximately two and one-half months after they filed suit, Hall and Roffey dismissed their claims against Payne and Rice.

Guest counterclaimed, seeking to have Hall and Roffey sanctioned. Guest alleged that Hall's and Roffey's claims were "baseless, without merit, and brought likely for the purpose of harassing Guest." Several months later, Guest filed traditional and no-evidence motions for summary judgment. In her no-evidence motion for summary judgment, Guest asserted that the statements attributed to her could not constitute slander per se and that Hall and Roffey could not prove the elements of a claim of defamation per se. Hall and Roffey filed no response to Guest's motions for summary judgment, which were to be heard on November 8, 2007. On the day before the hearing, Hall and Roffey nonsuited their claims against Guest and Weldy.

On November 13, 2007, Guest notified Hall and Roffey's attorney that the trial court would hear her "Counterclaim/Motion for Sanction" on November 20. On November 15, Guest filed a brief in support of her request for sanctions, and, for the first time, included a specific request that the court include an award of sanctions against Hall and Roffey's attorney. Hall and Roffey filed a response opposing Guest's request for sanctions; they asserted that the counterclaim was not a motion, and objected that they received insufficient notice. Hall and Roffey's response also alleged that Guest had signed a release that waived her claims for sanctions, and that their voluntary nonsuit prevented the trial court from considering the sanctions request.

During the sanctions hearing, the trial court found that the counterclaim included a motion for sanctions and that Guest's request for sanctions had survived Hall and Roffey's nonsuit. The court ruled that the release did not prevent Guest from seeking sanctions. The trial court awarded monetary sanctions against Hall, Roffey, their attorney who filed the original petition, and the attorney's law firm with the purpose of reimbursing Guest for fees she incurred in defending the suit.

II. Appellate Issues

Hall, Roffey, their attorney, and his law office (collectively, the "sanctioned parties") raise five issues on appeal. Issue one contends that the trial court never acquired jurisdiction over Guest's sanctions claim against the lawyer and his law offices because the counterclaim did not seek such sanctions. Issue two asserts that the trial court never acquired jurisdiction over Guest's claim for sanctions against the attorney or his law office because there were no pending motions for sanctions naming them when Hall and Roffey dismissed their suit. Issue three argues that there was no evidence that the lawsuit was filed for "dishonest, discriminatory, or malicious purposes." Issue four argues that Guest did not present evidence to show that Hall's and Roffey's claims were "filed for purposes of harassment, delay, or to increase the costs of litigation." Issue five contends that Guest released or waived her sanctions claim.

III. Trial Court's Jurisdiction

In their first two issues, the sanctioned parties challenge the trial court's jurisdiction to adjudicate the sanctions issue. We find no error in the trial court's treatment of the counterclaim as a motion for sanctions and find no error in the trial court's exercise of jurisdiction over the attorney and his law offices.

When determining the nature of a document, courts look to the substance of the relief requested by the pleading and not merely the title given the document. Tex. R. Civ. P. 71 ("When a party has mistakenly designated any plea or pleading, the court, if justice so requires, shall treat the plea or pleading as if it had been properly designated."); see State Bar of Tex. v. Heard, 603 S.W.2d 829, 833 (Tex. 1980) ("We look to the substance of a plea for relief to determine the nature of the pleading, not merely at the form of title given to it.").

In our opinion, Guest's counterclaim clearly sought to invoke the trial court's authority to enter sanctions. The counterclaim specifically requested an award of reasonable attorney's fees under Chapter 10 of the Texas Civil Practice and Remedies Code and under Rule 13 of the Texas Rules of Civil Procedure, and alleged that the lawsuit was frivolous, groundless, brought in bad faith, and brought for the purpose of harassment. Rule 13 and Chapter 10 both authorize a trial court to impose sanctions. We find no error in the trial court's treatment of Guest's counterclaim as a motion for sanctions.

The sanctioned parties also assert that the trial court did not have jurisdiction to impose sanctions on their attorney because Guest's counterclaim did not specifically ask for sanctions against the attorney or his law offices. The sanctioned parties argue that Guest's assertion of her sanctions request against Hall and Roffey's attorney in a brief supporting her sanctions motion was insufficient to vest the trial court with jurisdiction to adjudicate the issue against the attorney.

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Victoria Hall, Holli Roffey, John C. Osborne, and the Law Offices of John C. Osborne, P.L.L.C. v. Roxane Guest and Leslie Weldy, (Tex. Ct. App. 2009).

Victoria Hall, Holli Roffey, John C. Osborne, and the Law Offices of John C. Osborne, P.L.L.C. v. Roxane Guest and Leslie Weldy (Victoria Hall, Holli Roffey, John C. Osborne, and the Law Offices of John C. Osborne, P.L.L.C. v. Roxane Guest and Leslie Weldy) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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