Ncnb Texas National Bank, Relator v. the Honorable Bill F. Coker, Judge, Respondent

Summary

The Texas Supreme Court granted a petition for mandamus, holding that the trial judge abused discretion by failing to apply the required substantial‑relation test when disqualifying counsel, and ordered the disqualification order vacated. The Court emphasized that a movant must show a preponderance of facts that the two representations are substantially related to create a genuine threat of disclosure of confidences.