George Haddy v. John W. Caldwell, Jr., 403 S.W.3d 544

Haddy and Ana hired Caldwell to pursue a medical-malpractice claim against Army physicians; federal court granted summary judgment for the defense.
Two years later, Haddy sued Caldwell for legal malpractice alleging Caldwell failed to designate an expert and file an expert report.
Caldwell moved for summary judgment on no-evidence grounds, asserting no evidence of negligence by Caldwell; Haddy attached an affidavit, the federal court order, and emails from physicians.
Haddy amended with a medical expert report but did not obtain a legal expert affidavit addressing breach and standard of care.
The trial court granted summary judgment on no-evidence grounds for lack of competent evidence on breach and causation; the court of appeals affirmed.
Haddy’s sole issue on appeal was overruled; the judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Caldwell was entitled to no-evidence summary judgment on legal malpractice arising from prior litigation.	Haddy contends evidence (including his affidavit and the federal order) shows breach and causation.	Caldwell argues there is no competent legal-evidence showing breach or causation; no legal-expert testimony.	No error; lack of expert causation evidence requires judgment for Caldwell.

Alexander v. Turtur & Assocs., Inc., 146 S.W.3d 113 (Tex. 2004) (requires expert testimony for causation in legal-malpractice suit arising from prior litigation)
Merrell Dow Pharmaceuticals, Inc. v. Havner, 953 S.W.2d 706 (Tex. 1997) (no-evidence standard; scinti ll a is insufficient for material facts)
McInnis v. Mallia, 261 S.W.3d 197 (Tex.App.--Houston [14th Dist.] 2008) (expert testimony required for causation in legal-malpractice)
Cantu v. Horany, 195 S.W.3d 867 (Tex.App.--Dallas 2006) (suit-within-a-suit burden; expert causation needed)
Ersek v. Davis & Davis, P.C., 69 S.W.3d 268 (Tex.App.--Austin 2002) (expert testimony required on standard of care and causation)