Rahul K. Nath, M.D. v. Texas Children's Hospital and Baylor College of Medicine, 446 S.W.3d 355

Dr. Rahul K. Nath, a former Baylor plastic surgeon, sued Baylor College of Medicine and Texas Children’s Hospital (the Hospital) starting in 2006 alleging defamation, tortious interference, negligence, and later intentional infliction of emotional distress; multiple amended petitions added allegations about a colleague’s (Dr. Shenaq’s) health.
The trial court repeatedly found allegations about Shenaq’s health irrelevant and admonished Nath; summary judgment ultimately dismissed Nath’s claims in June 2010.
The Hospital and Baylor sought and the trial court awarded large monetary sanctions (approximately $776,607 and $644,500) against Nath personally for filing baseless pleadings in bad faith and for improper purpose (leveraging irrelevant/time‑barred matters to obtain settlement).
The court of appeals affirmed; the Texas Supreme Court granted review focusing on due process limits on sanctions and proper assessment of sanction amounts.
The Supreme Court held the pleadings were sanctionable (time‑barred claims and improper use of irrelevant health information) and that visiting sanctions on Nath personally was supported by evidence of his active involvement; but remanded to reassess the amount because the trial court failed to analyze whether defendants’ delay/litigation conduct contributed to their own fee accrual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pleadings sanctions were proper	Nath: sanctions were excessive and not properly visited on the true offender	Hospital/Baylor: Nath actively participated and was the true offender; pleadings were baseless/improperly motivated	Sanctions proper: pleadings (time‑barred and irrelevant allegations to leverage settlement) were sanctionable and some evidence supports visiting sanctions on Nath personally
Whether sanctions violated due process (true‑offender/proportionality)	Nath: award punished client rather than attorney and was excessive	Hospital/Baylor: client’s personal conduct warranted personal sanctions; amount reflected defended fees	Due‑process test satisfied as to nexus and true offender, but proportionality review requires reassessment of amount
Whether trial court properly assessed monetary amount of sanctions	Nath: award excessive and trial court failed to consider relevant factors (including defendants’ role in causing fees)	Hospital/Baylor: trial court considered Low factors and award justified	Trial court abused discretion by failing to consider a relevant Low factor — the degree to which defendants’ own conduct caused their fees — remand to reassess amount
Waiver of excessiveness objection	Hospital/Baylor: Nath waived objection by not raising at trial	Nath: timely raised excessiveness in motion for new trial and constitutional challenge	Court: Nath did not waive the excessiveness argument; preserved issue

Low v. Henry, 221 S.W.3d 609 (Tex. 2007) (factors to consider in fixing monetary pleadings sanctions)
TransAmerican Natural Gas Corp. v. Powell, 811 S.W.2d 913 (Tex. 1991) (due‑process limits: nexus to conduct, true offender, and proportionality/non‑excessiveness)
Unifund CCR Partners v. Villa, 299 S.W.3d 92 (Tex. 2009) (appellate review: sanctions upheld if some evidence supports trial court)
GTE Communications Sys. Corp. v. Tanner, 856 S.W.2d 725 (Tex. 1993) (presumption that filings are made in good faith; burden on movant for sanctions)
Cire v. Cummings, 134 S.W.3d 835 (Tex. 2004) (abuse of discretion standard: reversal if ruling lacks reference to guiding rules and principles)