Jared Woodfill
The Beaumont Court of Appeals has upheld a Montgomery County district court order sanctioning former Harris County GOP Chair and unsuccessful House candidate Jared Woodfill for failure to respond to discovery requests in suit against a 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 (No. 09-23-00259-CV; April 1, 2025) arose from a June 2022 wrongful termination lawsuit filed in Harris County. On the hospital’s motion, venue was transferred to Montgomery County. In April 2023 the hospital filed a motion to compel discovery, alleging that Plaintiff failed to verify responses, answer interrogatories, or provide responses for requests for production. According to the hospital, Plaintff had originally filed suit in September 2021 but nonsuited the case after not responding to the hospital’s discovery requests. The new suit made the same claims, and the hospital’s discovery requests asked for the same information. After numerous extensions, Plaintiff eventually filed a deficient response and failed to produce any requested documents. All of this led up to the hospital’s motion to compel, which the trial court granted on May 1, 2023, ordering Plaintiff to provide complete responses and documents within 7 days.
A month later, Plaintiff had not responded, so the hospital filed a motion to enforce the order and show cause pursuant to TRCP 215.2. The trial court set the show-cause hearing on June 16, 2023. Neither Plaintiff nor his counsel, Woodfill, showed up at the hearing. The hospital put on evidence showing “a pattern in Woodfill’s practice to not respond to dispositive motions and later file a motion for new trial claiming other pressing matters.” The hospital further claimed that Woodfill nonsuited the original suit to avoid answering discovery. After the hearing, the trial court signed a Show Cause Order, finding sufficient cause that Woodfill violated the court’s order. The court directed Woodfill to appeal at a Show Cause Hearing on July 14, 2023 and notified him that sanctions would follow until he complied. A day prior to the hearing, Woodfill filed a motion for nonsuit, which the trial court granted. However, as the court noted, sanctions survived the nonsuit, and the hospital showed that it incurred substantial attorney’s fees and that Woodfill’s alleged inability to contact his client didn’t excuse his failure to respond to the motion to compel or show up at the hearings. The hospital’s counsel further stated that Woodfill followed the same pattern in other cases, and requested the trial court to consider attorney’s fees.
Woodfill did appear at this hearing, represented by counsel, who claimed that Woodfill’s firm had lost a lot of attorneys and paralegals and that the hospital’s discovery requests, the court’s orders, and the show cause hearing had basically slipped through the cracks. Woodfill further blamed his client, whom he alleged was working on a strawberry farm, for not responding and conceded that he should have nonsuited sooner. Woodfill also conceded that he hadn’t done anything in the case and should have reached out to the hospital’s attorneys and the court to explain the situation. An unimpressed trial court took Woodfill to the woodshed and signed an order imposing sanctions, requiring Woodfill to pay the hospital’s attorneys fees. Plaintiff and Woodfill appealed.
In an opinion by Justice Johnson, the court of appeals affirmed. First, the court held that Plaintiff had no standing to complain of sanctions assessed solely against his lawyer. Second, the court ruled that it had jurisdiction over the appeal of the post-judgment sanctions order on the basis that “a post-judgment imposition of monetary sanctions is a final appealable judgment when the sanctions are reduced to a judgment and the order would support execution thereon” (citations omitted). Having determined its jurisdiction, the court proceeded to review the sanctions award.
First, Woodfill argued that the trial court erred and violated his due process rights by holding a hearing on enforcing the court’s order without personal service on Woodfill’s client. Too bad he didn’t make that argument to the trial court, which would have preserved appeal. He also didn’t explain how his client’s rights were violated when Woodfill was the subject of the sanctions order. Second, Woodfill argued that the trial court should have determined who was at fault for the stonewalling, though Woodfill admitted that it was ultimately on him. The court disagreed, finding that “the transcript of the contempt hearing reflects that the trial court questioned Woodfill about the circumstances and listened to the testimony of Woodfill, [so] we cannot say that the trial court did not attempt to determine the locus of responsibility” (citation omitted). And because the trial court’s reasons for imposing sanctions were supported by the record, the court concluded “that the sanctions imposed on Woodfill bear a direct relationship to the offensive conduct.” Last but not least, Woodfill tried to argue that the hospital’s attorney’s fees were unreasonable and unnecessary. Again, he didn’t put this argument to the trial court, but even if he had, he cited no authority supporting his position. No error.
As an aside, Woodfill alleged that the hospital’s local counsel “was one of the top donors to the trial judge’s election campaign,” which had nothing to do with whether the attorney’s “requested rates were in line with those prevailing in the community for similar services by lawyers with reasonably comparable skill, experience, and reputation” (citation omitted). Here the hospital’s lawyers testified about their experience and billing rates, which were customary in the area for attorneys of comparable experience and ability. The hospital adduced evidence of time spent on the discovery issues, billing rate, dates of service, and employee names for the hospital, and Woodfill’s attorney had the opportunity to cross-examine the attorneys at the hearing. Woodfill failed to request findings of fact and conclusions of law. The court of appeals thus deferred to the trial court’s assessment based on the record. The sanctions imposed were not excessive.
