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in Re: Tunad Enterprises, Inc.

Citation: Not availableDocket: 05-18-00980-CV

Court: Court of Appeals of Texas; September 12, 2018; Texas; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, the relator, a corporation, sought a writ of mandamus against a trial court's order denying its request for attorney's fees from a previous proceeding and the lack of findings of fact and conclusions of law. Additionally, the trial court had verbally directed the relator to comply with discovery requests and imposed $10,000 in sanctions, with payment required before trial, despite the relator's financial constraints. The relator argued that these actions warranted mandamus relief. The court, however, determined that the relator did not meet the criteria for such relief, as an adequate appellate remedy was available through an ordinary appeal for the denial of attorney's fees. Furthermore, the court noted the absence of a written order or a reporter’s record for the trial court's verbal rulings, rendering them non-reviewable by mandamus. Citing relevant case law, the court emphasized that verbal directives are only reviewable if they are clear, specific, and enforceable. Consequently, the court denied the petition for mandamus, affirming the relator's obligation to seek relief through standard appellate procedures.

Legal Issues Addressed

Mandamus Relief Requirements

Application: The court determined that the relator did not qualify for mandamus relief because there was an adequate remedy available through an ordinary appeal concerning the denial of attorney's fees.

Reasoning: To qualify for mandamus relief, relator must demonstrate a clear abuse of discretion by the trial court and an absence of adequate appellate remedy. The court concluded that relator did not satisfy this requirement, as it had an adequate remedy through an ordinary appeal regarding the denial of attorney's fees.

Reviewability of Verbal Rulings

Application: The court found that verbal rulings from the trial court were not subject to mandamus review due to the lack of a signed written order or a reporter’s record, thus not meeting the criteria for reviewability.

Reasoning: Regarding the verbal rulings, the court highlighted the absence of a signed written order or a reporter’s record of the hearing, which rendered the verbal rulings not subject to mandamus review.

Sanctions and Discovery Orders

Application: Despite the trial court's imposition of sanctions and orders for discovery responses, the relator failed to demonstrate a lack of adequate remedy, as these issues could be addressed through an appeal.

Reasoning: The trial court also verbally compelled relator to respond to discovery, imposed $10,000 in sanctions, and required payment before trial, despite relator's claims of inability to pay.