In Deutsch v. Hoover, Bax & Slovacek, L.L.P., 97 S.W.3d 179 (Tex. App. 2002), the Texas court considered the legal sufficiency of a client's claims for breach of fiduciary duty in connection with an attorney fee dispute. The court analyzed the issue by examining the precise actions taken by the attorney and classifying them, in the light most favorable to the client (as the non-moving party), as legal negligence, breach of contract, breach of fiduciary duty, or some other claim. Deutsch, pp. 187-189. The client presented a disputed question of fact as to whether the lawyer had agreed to bill his work based on the actual time he expended or in quarter-hour increments. The court held this controversy about billing procedures pertained to the agreement between the client and lawyer. Implicit in the holding was the conclusion that the fee dispute did not implicate the lawyer's fiduciary duty. However, the court concluded there were genuine issues of material fact as to whether the law firm breached its fiduciary duty by engaging in representation that constituted a conflict of interest. Deutsch, p. 192.