Brenda Dove v. R. Norvell Graham, Jr., Law Offices of Ralph Brown, P.C. and David Ross, 358 S.W.3d 681

Dove, injured in a 2001 car accident, hired Attorneys to sue Kraft.
May 2003: Attorneys filed suit against Kraft.
Case delayed by multiple continuances; trial held Jan. 14, 2008.
On the trial day, Attorneys sought and were denied a further continuance; Dove alleges they nonsuited without her approval.
Dove sued for legal malpractice in March 2009; Attorneys designated Kraft as a responsible third party and later cross-claimed against him after locating Kraft in California.
Kraft and Attorneys each moved for summary judgment; trial court granted the Attorneys’ traditional motion and severed the judgment; Dove appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Causation whether revival defeated causation	Dove argues delay/nonsuit caused harm that persists despite revival.	Attorneys contend Kraft’s revival cures harm; no causation.	No; revival does not conclusively disproves causation.
Effect of designation/joinder as cure	Designation/joinder cures the claim against Attorneys.	Cure does not negate the malpractice harm.	Designation/joinder does not conclusively negate causation.
Standard of review for traditional summary judgment	Argues genuine issues of material fact remain.	Movants must show no genuine fact issues and entitlement to judgment.	De novo review; issues must be conclusively established.
Severance preservation on appeal	Severance merits review.	Appellant failed to brief severance.	Appeal on severance denied for lack of argument.

Belt v. Oppenheimer, Blend, Harrison & Tate, Inc., 192 S.W.3d 780 (Tex. 2006) (causation in legal malpractice requires proof of injury but-for breach)
Elliott-Williams Co. v. Diaz, 9 S.W.3d 801 (Tex. 1999) (suit-within-a-suit to prove damages elements)
Akin, Gump, Strauss, Hauer & Feld, L.L.P. v. Nat’l Dev. & Research Corp., 299 S.W.3d 106 (Tex. 2009) (damages measure in malpractice actions)