• Business & Commercial
• Cargo Liability
• Catastrophic Loss
• Commercial Transportation
• Construction
• Energy Services Liability
• Maritime
• Premises Liability
• Products Liability
• Professional Liability

• Texas Bar

• All Texas state courts
• United States District Court, Southern District of Texas
• United States District Court, Eastern District of Texas
• United States District Court, Western District of Texas
• United States District Court, Northern District of Texas
• Fifth Circuit Court of Appeals
• U.S. Supreme Court

• The University of Texas, Bachelor of Journalism, 1989
• South Texas College of Law, Doctor of Jurisprudence, 1995

• A-V Preeminent Rating Martindale-Hubbell
• Order of Lytae, South Texas College of Law

• Deacon, Sugar Land Baptist Church

Available upon request.

• Hadel v. Morris, 2024 U.S. Dist. LEXIS 161165, (S.D. Texas July 12, 2024) (obtaining summary judgment on behalf of client under doctrine of restitutio in integrum) (publication anticipated)
• Brown v. Edwards & Richter, LLP, Fed. Appx. 30 (5th Cir. 2019) (concerning Limitation of Liability Act)
• In re Turney, 525 S.W.3d 832 (Tex. App.—Houston [14th Dist.] 2017, orig. proceeding) (granting, in part, mandamus on trial court’s failure to conduct in camera review of plaintiff’s medical records)
• In re Lloyd’s Register N. Am., Inc., 780 F.3d 283 (5th Cir. 2015) (mandamus proceeding involving Classification Society’s responsibility for certifying ships)
• Starr Indem. & Liab. Co. v. SGS Petroleum Serv. Corp., 719 F.3d 700 (5th Cir. 2013) (concerning buy-back provision in bumbershoot policy)
• In re Macy’s Tex., Inc., 291 S.W.3d 148 (Tex. 2009) (granting mandamus in favor of client compelling arbitration)

Recent Authorships:

• U.S. Supreme Court’s Unanimous Opinion Enforcing Maritime Choice of Law Provisions – How May it Implicate Uberrimae Fidei in Texas and Fifth Circuit, Transportation Lawyers Association, July 2024, Vo. 26, No. 1

Recent Trials and Arbitrations:

• Unanimous Defense Verdict
  A unanimous 12-person jury in Denton County, Texas found that Cox P.L.L.C.’s clients, a national trucking company and its driver, were not negligent in an April 19, 2019 three-car accident on Interstate 35 North. Plaintiffs were seeking $1 million. The jury returned a verdict within 45 minutes, answering “No” on the separate negligence questions for each plaintiff, one, a 93-year-old World War II veteran, and the other, his 74-year-old caretaker.
• Client Wins Arbitration | Awarded Attorney’s Fees
  Cox P.L.L.C.’s client, a global consulting firm and its director, won a complete defense award following a one-week JAMS Arbitration proceeding in Houston.. The arbitrator, a former United States federal district court judge, issued a 37-page Opinion and Interim Award on February 15, 2022, finding for Client on all causes of action and awarding our Client, as prevailing party, its attorney’s fees, costs, and expenses. The Claimant was an entrepreneur and inventor of novel anti-corrosion technology designed to remove contaminants and other corrosive materials from concrete, metal, and other structural surfaces in the oil and gas industry. After years patenting, modifying, and re-patenting his technology with little financial success, Claimant retained Tracy’s client to disentangle him from an unfavorable business deal and to assist on strategy and governance for launching world-wide product sales. Client successfully extricated Claimant from the failed venture where he was a minority owner in a company that owned his technology and had the exclusive marketing rights to the technology. However, Claimant later regretted the deal and filed suit against our Client and its director in Harris County state district court, alleging breach of fiduciary duty, fraudulent misrepresentation, fraud by nondisclosure, fraudulent inducement, civil conspiracy, aiding and abetting, and punitive damages. We successfully compelled the case to arbitration. Claimant sought to recover approximately $1.8 million in actual damages plus three-plus million dollars in punitive damages. Client prevailed on all claims. Claimant awarded no damages. Fees assessed against Claimant.
• Complete Exoneration for Client
  Tracy obtained complete dismissal of a claimant’s case following a bench trial in federal court in the Eastern District of Oklahoma. The case was filed under the Shipowner’s Limitation of Liability Act and may be the first one of its kind tried in the Eastern District of Oklahoma. Tracy’s client was operating his ski boat on Lake Texoma when it traversed wakes left by a larger vessel. The claimant, who was sitting at the bow of the client’s boat, reportedly bounced up three times, landed on the floor and reportedly sustained multiple fractures in his back.  Claimant alleged client was traveling at an unsafe speed and that he failed to keep a proper lookout. At the conclusion of the claimant’s case in chief, Tracy moved for judgment on partial findings that their client should be entitled to complete exoneration. The trial judge granted the motion, finding that the claimant did not sustain his burden of proof necessary for a finding of negligence. Client was completely exonerated.