A trial court may be authorized to impose sanctions against a party or a party's attorney by rule, statute, or its inherent authority. See, e.g., TEX. R. CIV. P. 13; TEX. CIV. PRAC. &REM. CODE ANN. §§ 10.001-.006; Phillips v. Am. Bankers Ins. Co. of Fla., No. 01-18-00375-CV, 2019 WL 3121856, at *7 (Tex. App.-Houston [1st Dist.] July 16, 2019, pet. denied) (mem. op.) ("A trial court possesses the inherent authority to impose sanctions for a bad faith abuse of the judicial process even when the specific conduct is not covered by a rule or statute.").
A trial court may be authorized to impose sanctions against a party or the party's attorney by rule, statute, or inherent authority. See, e.g., Tex.R.Civ.P. 13 (Effect of Signing Pleadings, Motions and Other Papers; Sanctions); Tex. Civ. Prac. & Rem. Code §§ 9.001-.014 (Frivolous Pleadings and Claims); id. §§ 10.001-.006 (Sanctions for Frivolous Pleadings and Motions); Phillips v. Am. Bankers Ins. Co. of Fla., No. 01-18-00375-CV, 2019 WL 3121856, at *7 (Tex. App.-Houston [1st Dist.] July 16, 2019, pet. denied) (mem. op.) ("A trial court possesses the inherent authority to impose sanctions for a bad faith abuse of the judicial process even when the specific conduct is not covered by a rule or statute.").
However, "findings of fact" made in support of a sanctions order are not treated as findings under Rule of Civil Procedure 296. Phillips v. Am. Bankers Ins. Co. of Fla., No. 01-18-00375-CV, 2019 WL 3121856, at *6 (Tex. App.-Houston [1st Dist.] July 16, 2019, pet. denied) (mem. op.)
A trial court may be authorized to impose sanctions against a party or a party's attorney by rule, statute, or its inherent authority. See, e.g., Tex.R.Civ.P. 13; Tex. Civ. Prac. & Rem. Code Ann. §§ 10.001-.006; Phillips v. Am. Bankers Ins. Co. of Fla., No. 01-18-00375-CV, 2019 WL 3121856, at *7 (Tex. App.-Houston [1st Dist.] July 16, 2019, pet. denied) (mem. op.) ("A trial court possesses the inherent authority to impose sanctions for a bad faith abuse of the judicial process even when the specific conduct is not covered by a rule or statute.").
Our review is not limited to evaluating the sufficiency of the evidence supporting the order. Phillips v. Am. Bankers Ins. Co. of Fla., No. 01-18-00375-CV, 2019 WL 3121856, at *6 (Tex. App.-Houston [1st Dist.] July 16, 2019, pet. denied) (mem. op.)
A trial court may be authorized to impose sanctions against a party or the party's attorney by rule, statute, or inherent authority. See, e.g., Tex.R.Civ.P. 13 (Effect of Signing Pleadings, Motions and Other Papers; Sanctions); Tex. Civ. Prac. & Rem. Code §§ 9.001-.014 (Frivolous Pleadings and Claims); id. §§ 10.001-.006 (Sanctions for Frivolous Pleadings and Motions); Phillips v. Am. Bankers Ins. Co. of Fla., No. 01-18-00375-CV, 2019 WL 3121856, at *7 (Tex. App.-Houston [1st Dist.] July 16, 2019, pet. denied) (mem. op.) ("A trial court possesses the inherent authority to impose sanctions for a bad faith abuse of the judicial process even when the specific conduct is not covered by a rule or statute.").
These authorities do not support the requested relief. See Phillips v. Am. Bankers Ins. Co. of Fla., No. 01-18-00375-CV, 2019 WL 3121856, at *8 (Tex. App.- Houston [1st Dist.] July 16, 2019, pet. denied) (stating that "[t]he Disciplinary Rules do not empower or otherwise operate as a source of authority to impose sanctions" and that "a violation of the Disciplinary Rules by [a party's] attorney cannot be attributed to [the attorney's] non-lawyer client").