citation_id,filing_id,case_name,citation,court,year,proposition,cited_by 124,17,"Regency Field Services, LLC v. Swift Energy Operating, LLC",622 S.W.3d 807,Tex.,2021,Defendant seeking summary judgment on limitations must conclusively establish that limitations expired before suit was filed; must negate discovery rule; claim accrues when defendant's wrongful conduct causes legal injury,Pohl 125,17,Burns v. Rochon,190 S.W.3d 263,Tex. App.—Houston [1st Dist.],2006,Conversion claim accrues at time of defendant's unlawful taking,Pohl 126,17,Pemex Exploracion y Produccion v. BASF Corp.,2013 WL 5514944,S.D. Tex.,2013,Each possession of converted property is a new conversion (applying Texas law),Pohl 127,17,Sw. Energy Prod. Co. v. Berry-Helfand,491 S.W.3d 699,Tex.,2016,Trade secret misappropriation accrues when the trade secret is actually used commercially; use means commercial use by which the offending party seeks to profit,Pohl 128,17,"Agar Corp., Inc. v. Electro Circuits Int'l, LLC",580 S.W.3d 136,Tex.,2019,Civil conspiracy accrues as to each underlying tort when that tort occurs,Pohl 129,17,Burchfield v. Prosperity Bank,408 S.W.3d 542,Tex. App.—Houston [1st Dist.],2013,"Res judicata requires prior final judgment, identity of parties or those in privity, and second action based on same claims that were or could have been raised; three-part test for privity: control, representation of interests, successor in interest",Pohl 130,17,Amstadt v. U.S. Brass Corp.,919 S.W.2d 644,Tex.,1996,"Three tests for privity: control over action, interests represented by a party, successor in interest",Pohl 131,17,Rogers v. Walker,2013 WL 2298449,Tex. App.—Corpus Christi,2013,Allegations of conspiracy alone insufficient to establish privity; movant must show one of three privity tests is satisfied; refusing to affirm summary judgment when movant did not state interest or evidence of representation,Pohl 132,17,"New York Pizzeria, Inc. v. Syal",53 F. Supp. 3d 962,S.D. Tex.,2014,Texas Supreme Court would not adopt blanket rule that coconspirators are always in privity for claim preclusion; courts must consider circumstances,Pohl 133,17,"McNeil Interests, Inc. v. Quisenberry",407 S.W.3d 381,Tex. App.—Houston [14th Dist.],2013,Privity through control requires active and open participation in prior proceedings to such extent it was clear the individual had right to direct them,Pohl 134,17,Citizens Ins. Co. of Am. v. Daccach,217 S.W.3d 430,Tex.,2007,"For res judicata, court looks to factual matters making up the gist of the complaint without regard to form of action; considers relatedness in time, space, origin, motivation; considers whether facts form a convenient trial unit",Pohl 135,17,Barr v. Resolution Tr. Corp. ex rel. Sunbelt Fed. Sav.,837 S.W.2d 627,Tex.,1992,Subsequent suit barred if it arises out of same subject matter AND could have been litigated in prior suit through exercise of diligence,Pohl 136,17,Youngkin v. Hines,546 S.W.3d 675,Tex.,2018,Two inquiries for attorney immunity: type of conduct and existence of attorney-client relationship at the time; conduct must be within scope of representation and not foreign to duties of a lawyer,Pohl 137,17,"Cantey Hanger, LLP v. Byrd",467 S.W.3d 477,Tex.,2015,Attorney immunity requires conduct within scope of client representation that is not foreign to duties of attorney; the kind of conduct in which an attorney engages when discharging duties to client,Pohl 138,17,"Landry's, Inc. v. Animal Legal Def. Fund",2021 WL 2021130,Tex.,2021,"Attorney immunity requires conduct in 'uniquely lawyerly capacity' particular to the office, professional training, skill, and authority of an attorney",Pohl 139,17,"Tanox, Inc. v. Akin, Gump, Strauss, Hauer & Feld, L.L.P.",105 S.W.3d 244,Tex. App.—Houston [14th Dist.],2003,Attorney-client relationship cannot be formed prior to 'meeting of the minds' between potential client and attorney,Pohl 140,17,Kassab v. Pohl,612 S.W.3d 571,Tex. App.—Houston [1st Dist.],2020,"First Court of Appeals characterized Kassab's conduct as arising from commercial transaction involving legal services; Pohl argues this does not establish attorney immunity, as it addresses scope of transaction not scope of duties to client",Pohl 141,17,RSM Prod. Corp. v. Freshfields Bruckhaus Deringer U.S. LLP,800 F. Supp. 2d 182,D.D.C.,2011,"Distinguished by Pohl: in RSM, plaintiff attempted to assert the exact same conspiracy in a new action; here the conspiracy was not part of the Federal Court Case",Pohl