Summary Judgment Attorney's Fee Awards Must Be Supported by Some Facts in East Texas

The Ninth Court of Appeals in Beaumont, Texas through a panel of Justices David Gaultney, Charles Kreger, and Hollis Horton held in a memorandum opinion that the evidence of attorney's fees in a collections case was insufficient to support a grant of summary judgment as to those fees. The attorney's fee affidavit in that case failed to state any hourly rate, or amount of time spent working on the case or any other specific facts behind the fee.Summary Judgments in Texas: Practice, Procedure, and Review