Texaco v. Pennzoil

In Texaco v. Pennzoil, 729 S.W.2d 768, 855 (Tex. App.--Houston 1st Dist. 1986, writ. ref'd n.r.e), the trial judge referred the motion to recuse to the administrative judge, who determined the motion to recuse. Texaco, 729 S.W.2d 768 at 853. The administrative judge found that the reason stated in the motion to recuse the trial judge was not valid and refused to hold a further hearing on the matter. Id. at 852. The issue in Texaco was not whether the trial judge could determine the validity of the motion on its face before deciding to recuse or refer. Rather, the issue presented in Texaco was whether the administrative judge was required to hold an evidentiary hearing on the motion to recuse before denying it. Id. Thus, it was in this context that we recognized that "while rule 18a does mandate a hearing on a motion to recuse, such requirement is not triggered unless the recusal motion states valid grounds for disqualification." Id. at 855.