Rahul K. Nath, M.D. v. Texas Children's Hospital and Baylor College of Medicine, 576 S.W.3d 707

Dr. Rahul Nath sued Texas Children’s Hospital and Baylor College of Medicine; the trial court found his claims frivolous and awarded the defendants $1.4 million in attorney’s fees as sanctions.
This is the second appeal: in Nath I the Texas Supreme Court agreed the claims were groundless but remanded to reassess the fee award because the defendants had litigated merits issues for years before seeking sanctions.
On remand the defendants submitted affidavits asserting the total fees billed and that they did not prolong the suit; the trial court reinstated the full $1.4 million award under Chapter 10 and Rule 13.
Nath challenged the sufficiency of the affidavits, arguing the defendants failed to prove the fees were reasonable and necessary.
Defendants argued a different, more lenient evidentiary standard should apply to fee sanctions because sanctions are punitive/deterrent.
The Court concluded that fee-shifting sanctions still require evidence of reasonableness (e.g., lodestar support such as billing records or detailed affidavits) and reversed and remanded for further proceedings consistent with Rohrmoos.

Issue	Plaintiff's Argument (Nath)	Defendant's Argument (Hospital/Baylor)	Held
Whether attorney’s-fee sanctions require proof of reasonableness and necessity	Affidavits here were insufficient; defendants must prove fees are reasonable and necessary	Sanctions are punitive/deterrent so a lesser evidentiary showing should suffice	Court held fee-shifting sanctions do require some affirmative evidence of reasonableness and causation
Whether conclusory affidavits showing total fees suffice	The affidavits do not show reasonable hours or rates	Totals billed should be adequate to support sanctions	Court held conclusory affidavits are legally insufficient; billing records or detailed support required
Whether Brantley v. Etter eliminated need for fee proof in sanctions	N/A (relies on precedent)	Reliance on Brantley supports deference to trial court discretion without detailed proof	Court clarified Brantley was misunderstood; discretion remains but requires evidentiary support for reasonableness
Whether remand is required for further proceedings after Rohrmoos	N/A	The trial court’s reinstated award should stand	Court reversed appellate affirmance and remanded to trial court for proceedings consistent with Rohrmoos and evidentiary requirements

Nath v. Tex. Children’s Hosp., 446 S.W.3d 355 (Tex. 2014) (earlier opinion finding claims groundless and remanding to reassess fee award)
Brantley v. Etter, 677 S.W.2d 503 (Tex. 1984) (per curiam) (trial court discretion over amount of fee sanctions; no jury trial right on amount)
PR Invs. & Speciality Retailers, Inc. v. State, 251 S.W.3d 472 (Tex. 2008) (sanction must be no more severe than necessary)
TransAmerican Nat. Gas Corp. v. Powell, 811 S.W.2d 913 (Tex. 1991) (guidance on sanctions and limits on severity)
Low v. Henry, 221 S.W.3d 609 (Tex. 2007) (sanctions should not be assessed without appropriate guidelines)
CHRISTUS Health Gulf Coast v. Carswell, 505 S.W.3d 528 (Tex. 2016) (burden to present affirmative evidence tying fees to sanctionable conduct)
Long v. Griffin, 442 S.W.3d 253 (Tex. 2014) (overturning fee award when supporting affidavit offered only generalities)
El Apple I, Ltd. v. Olivas, 370 S.W.3d 757 (Tex. 2012) (insufficiency of fee evidence based on generalities)
In re Nat’l Lloyds Ins. Co., 532 S.W.3d 794 (Tex. 2017) (party seeking fees bears burden to establish reasonableness)