The breadth of the ruling in Westview Drive Investments, LLC v. Landmark American Ins. Co., No. 14-15-00574-CV (Tex. App.-Houston [14th Dist.] Feb. 28, 2017) is unknown. But, it cannot go without notice.

Judicial Canon 3(D)(2) provides that: "A judge who receives information clearly establishing that a lawyer has committed a violation of the Texas Disciplinary Rules of Professional Conduct should take appropriate action."

The COA held that this means the trial court can itself impose sanctions under its inherent authority. It is not limited to referring the matter to the State Bar. That could be problematic for several reasons.