Nath v. Texas Children's Hospital (Per Curiam)Annotate this Case
In this appeal of a $1.4 million sanction levied to compensate Respondents, the prevailing parties, for their attorney's fees in defending against a frivolous lawsuit, the Supreme Court reversed the court of appeals' judgment affirming the sanctions award and remanded the case to the trial court for further proceedings, holding that the standard for fee-shifting awards in Cf. Rohrmoos Venture v. UTSW DVA Healthcare, LLP, __ S.W.3d __ (Tex.2019), likewise applies to fee-shifting sanctions.
In the first appeal, the Supreme Court concluded that Petitioner's pleadings were groundless and sanctionable and remanded for the trial court to reassess its award of attorney's fees. On remand, the trial court reassessed the same $1.4 million sanction originally granted for attorney's fees. On appeal, Petitioner argued that Respondents' affidavits were insufficient to prove that the $1.4 million sanction was a reasonable and necessary attorney's fee. In response, Respondents argued that a different standard of proof applies for attorney's fees awarded as sanctions because the purpose of sanctions is to punish violators and deter misconduct. The Supreme Court disagreed, holding that all fee-shifting situations require reasonableness and that conclusory affidavits containing mere generalities about the fees for working on Petitioner's frivolous claims are legally insufficient to justify the sanction awarded in this case.