Roberts v. Southwest Texas Methodist Hospital

ON APPELLEE’S MOTION FOR REHEARING

The hospital’s motion for rehearing says that we required that its motion for summary judgment be too precise, and that if Roberts wanted to confine the hospital to the two grounds stated in its motion, she should have excepted to it. It is true that defects in summary judgment motions are comparable to other pleading defects. In 1978 the supreme court held that “the failure of a motion for summary judgment to specify grounds is a defect of form that is waived unless excepted to prior to rendition of judgment.” Westchester Fire Ins. Co. v. Alvarez, 576 S.W.2d 771, 778 (Tex.1978). The court likened summary judgment motions to ordinary pleadings and applied the waiver provisions of rule 90 to them. Id.

But here the hospital’s motion did not fail to specify grounds. It specified two grounds (limitations and no duty to obtain informed consent), and the hospital seeks now to uphold the judgment on two other grounds (that article 4590i, § 6.02 abolished the cause of action for battery and that as a matter of law its nurses did not aid and encourage the doctor). The Westchester rule was not meant to extend to this situation.

When a motion states no grounds, it suffers from a pleading defect and does not satisfy rule 166a. But that pleading defect is waived if it is not asserted in the trial court. TEX.R.CIV.P. 90; TEX. R.APP.P. 52(a); University of Texas v. Joki, 735 S.W.2d 505, 507 (Tex.App.—Austin 1987, writ denied); C.S.R., Inc. v. Mobile Crane, Inc., 671 S.W.2d 638, 640-41 (Tex.App.—Corpus Christi 1984, no writ); Inwood Forest Community Improvement Assoc. v. R.J.S. Dev. Co., 630 S.W.2d 751, 753 (Tex.App.—Houston [1st Dist.] 1982, no writ). In contrast, a motion that states certain grounds but not others is not defective as a matter of pleading, and the respondent need not except to it. One who is sued on two specific theories of recovery has no duty to except to the petition and ask whether there are other theories that the pleader wants to allege. The same thing is true of summary judgment motions.

We note that the version of rule 166-A1 at issue in Westchester said simply that “the motion for summary judgment shall state the specific grounds therefor.” Effective January 1, 1978, rule 166-A was amended to say that the court should grant the motion if the summary judgment proof shows that there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law “on the issues as expressly set out in the motion or in an answer or any other response.” TEX.R.CIV.P. 166a (Vernon Supp. 1991, historical note).

In City of Houston v. Clear Creek Basin Auth., 589 S.W.2d 671 (Tex.1979), the supreme court stressed the rule’s new language — that the movant must show himself entitled to judgment as a matter of law “on the issues as expressly set out in the motion” — and held that “[t]he ‘issues’ required by the rule to be ‘expressly presented’ are those pointed out to the trial court in written motions, written answers or written responses to the motion.” Id. at 677. If the parties want to expand or restrict the issues expressly presented in the motion, said the court, they must do so *146in compliance with rule 11. Id. Any agreement to alter the issues presented in the motion must be in writing, signed, and filed, or must be made in open court on the record. Rule 11 is satisfied if the agreement to expand the issues is described in the court’s judgment or order. Id. Our record does not show that an agreement was made in writing, stated on the record in open court, or recited in the judgment. Thus the hospital has not satisfied Clear Creek’s holding that any agreement to expand the issues beyond those specified in the motion must comply with rule 11.

There is nothing onerous or unreasonable about requiring the movant to state the grounds upon which he seeks to win a lawsuit without a trial. If the grounds are so obvious from the summary judgment proof, what is burdensome about requiring the movant to state them in the motion? Grounds may be stated concisely, without detail and argument. But they must at least be listed in the motion. When a motion for summary judgment asserts grounds A and B, it cannot be upheld on grounds C and D, which were not asserted, even if the summary judgment proof supports them and the responding party did not except to the motion.

Under rule 166a(c) and Clear Creek, the hospital as movant had the burden to include in its motion any grounds that it wanted to assert in the trial court and in this court. We hold that Roberts had no duty to except to the hospital’s specific motion, which urged two grounds, in order to avoid trying by consent two other grounds that might have been found in the evidence and the trial brief.

The dissent says that § 6.02 was before the court because the hospital’s response to Roberts’s motion for partial summary judgment addressed it. But the court did not hear Roberts’s motion when it granted the hospital’s motion. It simply sustained various objections to Roberts’s motion that day. In any event, the discussion of a legal issue in the hospital’s response to Roberts’s motion did not place that issue before the court because the hospital’s motion itself did not mention it.

We overrule the other grounds urged in the hospital’s motion for rehearing for the reasons stated in our original opinion.

The motion for rehearing is overruled.

. A 1988 amendment changed the rule’s number from 166-A to 166a.