Marshall Land v. AT & S Transportation, Inc.
Marshall Land sued his employer, AT & S Transportation, Inc., claiming a failure to provide a safe work environment after sustaining a back injury. AT & S, a nonsubscriber to the workers' compensation system, filed a counterclaim for sanctions under Rule 13 of the Texas Rules of Civil Procedure. The trial court awarded AT & S $48,000 in attorney's fees as sanctions against Land, finding his pleadings groundless, brought in bad faith, and false, and that Land committed fraud. Land appealed, arguing the sanctions order was defective for not stating particulars of good cause and that the court abused its discretion. The appellate court affirmed the trial court's judgment, holding that Land waived the complaint regarding lack of particularity by not objecting at trial and that the partial record provided was insufficient to demonstrate an abuse of discretion regarding the sanctions.