Ford Motor Co. v. Chacon, 370 S.W.3d 359

Guardian ad litem G. Daniel Mena was appointed to represent Valerie Chacon during the Cooper Tire settlement and the court approved the settlement.
Mena sought and the court awarded $11,000 for his guardian ad litem services related to the Cooper Tire settlement, payable by Cooper Tire.
After the Cooper Tire settlement, Mena continued to participate in the case against Ford and Brown without a written appointment.
In 2007, mediation yielded a separate settlement against Ford; Mena submitted an hour-by-hour bill for Valerie’s interests against Ford.
Ford objected, arguing Mena’s post-settlement work exceeded his appointment scope and raised potential double billing.
The trial court awarded $17,087 for Mena’s work against Ford, offset by the prior $11,000 paid for Cooper Tire, and the Court of Appeals reduced the rate and total award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mena’s post-Cooper Tire activities were within the guardian ad litem scope	Mena acted to protect Valerie’s interests in remaining claims.	Mena’s appointment ended with the Cooper Tire settlement; post-settlement work was beyond scope absent a written order.	Post-settlement work exceeded scope of appointment; not compensable.
Whether Rule 173 required a written appointment for Mena's Ford-related work	Appointment implied ongoing duty to Valerie’s interests.	No written order extended appointment; fees improper without order.	Without a written order extending appointment, Ford-related work was unauthorized.

Ford Motor Co. v. Garcia, 363 S.W.3d 573 (Tex. 2012) (defines scope and limits of guardian ad litem appointments)
Land Rover U.K., Ltd. v. Hinojosa, 210 S.W.3d 604 (Tex. 2006) (guardian ad litem duties and scope guidance)
Stewart Title Guar. Co. v. Sterling, 822 S.W.2d 1 (Tex. 1991) (burden on guardian ad litem to prove reasonableness of services)
Garcia (Ford Motor Co.), 363 S.W.3d 573 (Tex. 2012) (reiterates appointment scope analysis)