William Bloodworth, III v. Kristi Aden

CourtCourt of Appeals of Texas
DecidedJune 28, 2007
Docket01-05-00796-CV
StatusPublished

This text of William Bloodworth, III v. Kristi Aden (William Bloodworth, III v. Kristi Aden) 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.

Bluebook
William Bloodworth, III v. Kristi Aden, (Tex. Ct. App. 2007).

Opinion

Opinion issued June 28, 2007

Opinion issued June 28, 2007





In The

Court of Appeals

For The

First District of Texas


NO. 01-05-00796-CV


WILLIAM BLOODWORTH II, Appellant

V.

KRISTI ADEN, Appellee


On Appeal from the 278th District Court

Walker County, Texas

Trial Court Cause No. 14153C



MEMORANDUM OPINION

William Bloodworth II appeals the trial court’s order granting appellee Kristi Aden’s motion for sanctions.  In four issues, Bloodworth contends the trial court erred in submitting the sanctions issue to the jury, and in imposing a sanction against Bloodworth personally instead of against William D. Bloodworth II, PLLC.  We conclude that (1) any error in the submission of the sanctions issue to the jury was harmless, and (2) the trial court did not abuse its discretion in sanctioning Bloodworth personally.  We therefore affirm. 

Background

          Kristi petitioned the trial court to modify a child support order against her ex-husband, Steven Wayne Aden.  Steven hired Bloodworth to represent him in the lawsuit.  Bloodworth answered the lawsuit and filed a counterclaim on Steven’s behalf.  The counterclaim sought to modify the trial court’s conservatorship order.  Kristi moved for sanctions against Bloodworth, asserting that the counterclaim was frivolous and filed in violation of section 10.001 of the Texas Civil Practice and Remedies Code and Rule 13 of the Texas Rules of Civil Procedure.  See Tex. Civ. Prac. & Rem. Code Ann. § 10.001 (Vernon 2002); Tex. R. Civ. P. 13.

          Steven thereafter fired Bloodworth because he felt that Bloodworth had misled him with regard to filing a counterclaim.  The trial court granted Bloodworth’s motion to withdraw from his representation of Steven.  Bloodworth then intervened in the lawsuit between Steven and Kristi, asserting claims against Steven for breach of contract and sworn account, and challenging Kristi’s motion for sanctions.  Steven counterclaimed against Bloodworth, asserting claims for legal malpractice, fee forfeiture, and violations of the Deceptive Trade Practices Act.  Steven and Bloodworth, however, eventually nonsuited their claims against one another.

          At the hearing on the motion for sanctions, Steven testified that he never authorized Bloodworth to file the counterclaim to modify the conservatorship order.  Rather, Steven told Bloodworth simply that he would like more visitation with his daughter.  When Steven asked Bloodworth why he had filed the counterclaim to modify conservatorship, Bloodworth responded, “that’s the way us lawyers do that.  You know, give the Judge some playing room to go in there and settle for something in between.” 

          Kristi testified that she paid $25,000 to retain an attorney to defend the conservatorship counterclaim.  Kristi had to borrow money from her grandmother to pay the retainer.  Kristi’s attorney testified that he billed $32,131.83 in this case.

          Bloodworth testified that Steven came to his office and informed him of the various problems he was having with Kristi concerning custody of the couple’s daughter.  Bloodworth explained to Steven the various actions he could take to remedy the problems, and asked Steven to discuss the options with his most “trusted advisors.”  Bloodworth testified that Steven gave him permission to file the counterclaim to modify conservatorship.

          At the end of the hearing, the trial court submitted the sanctions issue to the jury.  The jury found that Steven’s counterclaim against Kristi seeking to modify the trial court’s conservatorship order was frivolous.  The jury also found that Bloodworth should pay Kristi $8,250 in attorney’s fees as a sanction for filing the frivolous counterclaim on Steven’s behalf.  The trial court entered an order against Bloodworth, stating:

IT IS ORDERED that the pleadings filed in this matter by William Bloodworth, III [sic] were found to be frivolous, groundless and baseless by a jury and this Court.  The fact that William Bloodworth, III [sic] filed fictitious pleadings causing this matter to become a custody issue in order to harass and intimidate Kristi Aden and against the wishes of his client, Steven Aden created a frivolous, groundless and baseless cause of action, with the intent to harass Kristi Aden.  Therefore, IT IS ORDERED by this Court that a money judgment is rendered against William Bloodworth, III [sic] as sanctions and in favor of Kristi Aden in the amount of $8,250.00.  Further, it is an ORDER of this Court that William Bloodworth, III [sic] make payment to Kristi Aden on or before 5:00 p.m. on _______________, 2005.

Jury Trial

          In his first three issues, Bloodworth contends the trial court erred in submitting the sanctions issue to the jury.

Filing a frivolous pleading is litigation misconduct subject to sanction under Chapter 10 of the Texas Civil Practice and Remedies Code and Texas Rule of Civil Procedure 13.  Tex. Civ. Prac. & Rem. Code Ann. §§ 10.001–10.006 (Vernon 2002); Tex. R. Civ. P. 13; Low v. Henry, 221 S.W.3d 609, 614 (Tex.

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