Heather Bailey New

Senior Attorney

Dallas


2323 Victory Avenue
Suite 700
Dallas, Texas 75219
T +1 214.651.5132
F +1 214.200.0530

Areas of Practice

Education

  • J.D., Baylor University School of Law, 1998, magna cum laude; Research and Topics Editor, Baylor Law Review; Regional Champion and National Semifinalist, American College of Trial Lawyers/Texas Young Lawyers Association Mock Trial Competition
  • B.A., Stephen F. Austin University, 1993, summa cum laude

Bar Admissions

  • Texas

Court Admissions

  • U.S. District Court for the Eastern District of Texas
  • U.S. District Court for the Northern District of Texas
  • U.S. District Court for the Southern District of Texas
  • U.S. District Court for the Western District of Texas
  • U.S. Court of Appeals for the Fifth Circuit

Judicial Clerkships

Briefing attorney for Justice Priscilla Owen at the Supreme Court of Texas from 1998-1999.
Heather Bailey New

In addition to providing traditional appellate assistance with brief writing, oral arguments, and mandamus filings, Heather New has experience in handling a wide range of legal issues that arise before a notice of appeal is ever filed. These include briefing on dispositive motions and motions for class certification, jury charge preparation, judgment formation, post-judgment motion practice, arbitration, and mediation.  Heather has served as appellate counsel in both state and federal appeals, and was recognized as a "Rising Star" in the practice of appellate law by Texas Monthly in 2005, 2007, 2010, and 2011. She served as briefing attorney for Justice Priscilla Owen at the Supreme Court of Texas from 1998-1999, prior to Justice Owen’s confirmation to the United States Fifth Circuit Court of Appeals.

Selected representations

  • After filing of opening appellate briefs, opponent agreed to settle commercial dispute for almost $200 million less than its judgment. i2 Technologies, Inc. v. Dillards, Cause No. 05-10-01645-CV (Tex. App. -Dallas 2011)
  • Persuaded the court of appeals to affirm the trial court's refusal to compel arbitration where none of the litigants were signatories to the contract containing the arbitration provision and plaintiffs' tort claims arose from conduct that occurred prior to the execution of the contract. Kurt Torster & GEA Group v. Panda Energy Mgmt., No. 07-10-0442-CV, 2011 Tex. App. LEXIS 1628 (Tex. App.-Amarillo Mar. 7, 2011, n.p.h.)
  • Assisted trial counsel with summary judgment briefing and, after prevailing, defended summary judgment on appeal in a products liability and negligence case involving a Trinity-manufactured guardrail end cap. Trinity's evidence demonstrated compliance with mandatory safety standards or regulations adopted and promulgated by the federal government under section 82.008 of the Texas Civil Practice and Remedies Code; Appellants did not rebut section 82.008's presumption of non-liability; and there was no more than a scintilla of causation evidence. Shaw v. Trinity Highway Products, LLC, No. 05-09-00561-CV, 2010 Tex. App. LEXIS 10046 (Tex. App.-Dallas, Dec. 20, 2010, n.p.h.)
  • Successfully defended on appeal a verdict in favor of purchasers of residential real estate who discovered that the seller failed to disclose substantial latent defects as required by the Texas Property Code, in violation of the Texas Deceptive Trade Practices Act. Bernstein v. Thomas, 298 S.W.3d 817 (Tex. App.-Dallas, Oct. 13, 2009, no pet.).
  • Convinced the Dallas Court of Appeals to grant mandamus relief directing the trial court to stay litigation pending the outcome of Nevada arbitration proceedings between The Ultimate Fighting Championship mixed martial arts fight promoter and fighter Randy Couture. In re Zuffa, LLC, No. 05-08-0666-CV, 262 S.W.3d 446, 2008 WL 3307125 (Tex. App.-Dallas July 31, 2008, orig. proceeding)
  • In a case of first impression, persuaded the Iowa Supreme Court unanimously to hold that a $2.5 million contribution claim was barred under that state's statute of repose for products manufacturers. Heritage Trails Assoc. et al. v. Trinity Indus., Inc., 745 N.W.2d 724 (Iowa 2008)
  • Successfully argued a negligence and punitive damages jury charge resulting in a take-nothing judgment in favor of client.  Doe v. Brookhaven Country Club, No. 04-10591-D, 95th Jud. Dist., Dallas County, 2006.
  • Assisted trial team in obtaining a take-nothing judgment on behalf of employer in a trial involving various employment claims.  Southern Council of Indus. Workers, Local 2104 v. Housing Authority of the City of Dallas, No. 02-06270-D, 95th Jud. Dist., Dallas County, 2005.
  • Served as lead appellate counsel in a state court appeal of a multi-million dollar arbitration award. (2005).
  • Assisted in obtaining affirmance of dismissal of qui tam action under False Claims Act. United States of America, ex rel Williams v. Bell,  417 F.3d 450 (5th Cir. 2005).
  • Successfully represented real estate company on interlocutory appeal of class certification of claims under the Telephone Consumer Protection Act and contemporaneously defended the company on appeal following the grant of summary judgment in the company’s favor.  Kondos v. Lincoln Property Co., 110 S.W.3d 716 (Tex. App.-Dallas 2003, no pet.).
  • Served as lead appellate counsel in obtaining issuance of conditional mandamus ordering the trial court to reinstate Pepsico’s amended motion to transfer venue. In re Pepsico, Inc., 87 S.W. 3d 787 (Tex. App.-Texarkana 2002, orig. proceeding).
  • Assisted in persuading the Fifth Circuit to reverse a $12 million damage award based on a complex contract dispute involving a hospital and pharmacy.  In re Liljeberg Enterprises, Inc., 304 F.3d 410 (5th Cir. 2002).
  • Assisted in obtaining reversal of $34 million lost profit award on behalf of Exxon Corporation. Exxon Corp. v. Breezevale, Ltd., 82 S.W.3d 429 (Tex. App.-Dallas 2002, pet. denied).
  • Persuaded the Dallas Court of Appeals to affirm summary judgment in favor of  media defendants against charges of libel and business disparagement on appeal.  Wheeler v. New Times, Inc., 49 S.W.3d 471 (Tex. App.-Dallas 2001, no pet.).

Selected Professional and Community Leadership

  • Selected for inclusion in Texas Super Lawyers - Rising Stars Edition, 2005, 2007, 2010-2011
  • Dallas Bar Association, former co-chair, Dallas Bar Publication Committee (led Headnotes publication to receive a first place Luminary Award given by the National Association of Bar Executives Communications Section)
  • Dallas Association of Young Lawyers Founding Fellow
  • 2000 DAYL Leadership Class
  • Named DAYL Rising Star in 2001
  • Former co-chair, DAYL Texas State Mentor Committee
  • Associate, Patrick E. Higginbotham American Inn of Court

Selected Representative Experience


i2 Technologies, Inc. v. Dillards, Cause No. 05-10-01645-CV, 2011 WL 6250787 (Tex. App.--Dallas, Dec. 14, 2011, no pet.)
After opening appellate briefs were filed, obtained a settlement of a commercial dispute in which the opposing party agreed to accept almost $200 million less than its judgment.

Kurt Torster & GEA Group v. Panda Energy Mgmt., No. 07-10-0442-CV, 2011 Tex. App. LEXIS 1628 (Tex. App.-Amarillo Mar. 7, 2011, pet. denied)
Persuaded the court of appeals to affirm the trial court's refusal to compel arbitration where none of the litigants were signatories to the contract containing the arbitration provision and plaintiffs' tort claims arose from conduct that occurred prior to the execution of the contract. Convinced the Texas Supreme Court to deny review after full briefing.

Shaw v. Trinity Highway Products, LLC, No. 05-09-00561-CV, 2010 Tex. App. LEXIS 10046 (Tex. App.-Dallas, Dec. 20, 2010, n.p.h.)
Assisted trial counsel with summary judgment briefing and, after prevailing, defended summary judgment on appeal in a products liability and negligence case involving a Trinity-manufactured guardrail end cap. Trinity’s evidence demonstrated compliance with mandatory safety standards or regulations adopted and promulgated by the federal government under section 82.008 of the Texas Civil Practice and Remedies Code; Appellants did not rebut section 82.008’s presumption of non-liability; and there was no more than a scintilla of causation evidence.

Bernstein v. Thomas, 298 S.W.3d 817 (Tex. App.—Dallas, Oct. 13, 2009, no pet.).
Successfully defended on appeal a verdict in favor of purchasers of residential real estate who discovered that the seller failed to disclose substantial latent defects as required by the Texas Property Code, in violation of the Texas Deceptive Trade Practices Act.

ASARCO LLC v. Americas Mining Corp. (In re ASARCO LLC), Adversary No. 07-02011 (S.D. Tex.)
Assisted bankruptcy and tax counsel with briefing and argument of novel issues of law and preservation of error in adversary proceeding between parent company and wholly-owned, "disregarded" entity over ownership of a $50 million tax refund, liability for more than $100 million in post-petition federal income taxes owed under tax sharing agreement, and liability for taxes attributable to $600 million deferred intercompany gain.

Hicks v. Trinity Industries, Inc., No. D-C-07-11221 (44th Dist., Dallas County, 2009)
Obtained favorable rulings on competing motions to exclude expert witnesses in a products liability action.

Heritage Trails Assoc. et al. v. Trinity Indus., Inc., 745 N.W.2d 724 (Iowa 2008)
In a case of first impression, persuaded the Iowa Supreme Court unanimously to hold that a $2.5 million contribution claim was barred under that state's statute of repose for products manufacturers.

Heritage Southwest Medical Group, Inc. v. PacifiCare of Texas, No. 01-05016 (14th Dist. Ct., Dallas County, Tex.)
Served as appellate counsel defending a state district court’s vacatur of an arbitration award.

Positive Software Solutions v. New Century Mortgage, et al., 476 F.3d 278 (5th Cir. 2007), cert. denied, 127 S. Ct. 2943 (2007) (en banc)
In the case that set the standard for vacatur of arbitration awards in the Fifth Circuit, persuaded en banc Fifth Circuit Court of Appeals to reverse order vacating arbitration award in favor of leading nationwide specialty mortgage-banking company, setting standard for vacatur in Fifth Circuit.

Reynolds v. Murphy, 188 S.W.3d 252 (Tex. App. - Fort Worth 2006, pet. denied)
Obtained the first appellate opinion in Texas protecting the First Amendment rights of a newsletter publisher and author to publish general investment advice.

United States ex rel. Williams v. Bell Helicopter Textron Inc., 417 F.3d 450 (5th Cir. 2005)
Obtained a judgment affirming the dismissal of qui tam action under the False Claims Act.

Burlington Northern and Santa Fe Railway Co. v. City of Houston, 171 S.W.3d 240 (Tex. App. - Houston [14th Dist.] 2005, no pet.)
Obtained reversal of a judgment denying a railroad's right to condemn property for a proposed rail line, resulting in rendition of a judgment confirming the railroad's right to condemn under the doctrine of federal preemption.

Texas First National Bank v. Wu, 347 F. Supp. 2d 389 (S.D. Tex. 2004)
Obtained remand from federal district court to state court in a case involving a dispute by bank officers over control of the bank.

Wheeler v. New Times, Inc., 49 S.W.3d 471 (Tex. App. --Dallas 2001, no pet.)
Persuaded a court of appeals to affirm a summary judgment in favor of media defendants against charges of libel and business disparagement.

Southern Council of Indus. Workers, Local 2104 v. Housing Authority of the City of Dallas, No. 02-06270-D (95th Dist. Ct., Dallas County, Tex.)
Assisted the trial team in preparing the jury charge and obtaining a take-nothing judgment on behalf of employer in a trial involving multiple employment claims.

Kondos v. Lincoln Property Co., 110 S.W.3d 716 (Tex. App. - Dallas 2003, no pet.)
In a case of first impression under the Telephone Consumer Protection Act, obtained reversal of an order certifying a class of more than 60,000 members who alleged “junk faxing” by a company that owns apartment complexes.

In re Pepsico, Inc., 87 S.W.3d 787 (Tex. App. - Texarkana 2002, orig. proceeding)
Obtained a conditional writ of mandamus ordering a trial court to reinstate a motion to transfer venue.

In the Matter of Liljeberg Enterprises, Inc., 304 F.3d 410 (5th Cir. 2002)
Obtained reversal of a $12 million award in a contract dispute involving severability and cross-default issues implicating the power to assume an executory contract.

Exxon Corp. v. Breezevale Ltd., 82 S.W.3d 429 (Tex. App. - Dallas 2002, pet. denied)
Obtained reversal of a $34.3 million judgment based on a jury verdict against an oil company in a suit involving a claimed oral agreement that was held to be barred by the statute of frauds.

McCutchin v. Addison Texas Tumbleweed, Inc., No. 05-98-01918-CV, 2001 WL 910940 (Tex. App. - Dallas Aug. 13, 2001, pet. denied) (mem. op.)
Obtained reversal of an adverse $1.2 million judgment in a wrongful eviction case and obtained a $100,000 judgment in favor of our client.

Zuffa, LLC v. HDNet MMA 2008 LLC, 262 S.W.3d 446 (Tex. App.-Dallas 2008, orig. proceeding)
Persuaded the Dallas Court of Appeals to grant mandamus relief directing the trial court to stay litigation pending the outcome of Nevada arbitration proceedings between The Ultimate Fighting Championship mixed martial arts fight promoter and fighter Randy Couture.

Doe v. Brookhaven Country Club, No. 04-10591-D (95th Dist. Ct., Dallas County, Tex.)
Argued a jury charge involving issues of negligence and punitive damages, resulting in a favorable take-nothing judgment.

Panda Energy v. Heard Energy Corp., No. 94-06762-L (193rd Dist. Ct., Dallas County, Tex.)
Served as trial and appellate counsel during three-month trial involving claims for breach of fiduciary duty, fraud, and conspiracy, drafted the jury charge and argued a multi-day charge conference, resulting in a favorable verdict.

Online Publications

09/02/2010 - Formation of the Judgment and Calculation of Interest
You are the winning party in a lawsuit, and the judge asks you to prepare a proposed judgment. You turn to the rules. Judgments are generally governed by Rules 300-316 of the Texas Rules of Civil Procedure. TEX. R. CIV. P. 300-16. You soon discover the rules aren’t much help, as only a handful address judgment formation. 

09/10/2009 - Federal and State Expert Testimony Under Daubert and Robinson: What's the Difference?
This paper explores the general requirements to proffer and seek review of the admission and exclusion of expert testimony in federal and state court. It focuses on the standards for admissibility, the role of experts in summary judgment proceedings, preservation, and standards of review on appeal in federal and state court. Along with a few practice tips, the article notes differences where discernible between federal and state court.

05/01/2009 - Challenging the Admissibility of Government Reports under the Rules of Evidence and Daubert/Robinson
Dallas Young Lawyers Association's The Dicta, Vol. 26, No. 5 (May 2009).

10/01/2008 - A Whole New World of Texas Mandamus Practice
Dallas Young Lawyers Association's The Dicta, Vol. 25, No. 10 (October 2008).

04/08/2008 - Determining the Precedential Value of Supreme Court Plurality Decisions in the Fifth Circuit
The Appellate Advocate, State Bar of Texas Appellate Section Report, Vol. 20, No. 2 (Winter 2007)

05/31/2007 - Federal Discretionary Appeals
This paper explores three types of permissive, discretionary appeals authorized by statute and federal procedural rules: (i) appeals of interlocutory orders under 28 U.S.C. § 1292(b); (ii) appeals of class certification orders under Federal Rule of Civil Procedure 23(f); and (iii) direct and interlocutory bankruptcy appeals.

06/23/2005 - The Charge: Top Five Things You Need to Know
State Bar of Texas Annual Meeting: Litigation Section (June 23, 2005)

05/13/2003 - The Court's Charge
Dallas Bar Association Business Litigation Section (May 13, 2003)

01/11/2002 - Court's Charge - Minefield Approach
When Do You Draft? It is never too early to start drafting your charge. Knowledge of how your charge will look will assist with the pleading, discovery, and proof aspects of your case. Indeed, advance knowledge of your charge will ensure that you not prove up the wrong case! The first big bad mistake of charge practice is waiting too long to draft the charge. A draft should be prepared at the outset of the case and updated throughout the pretrial process. You should avoid the temptation of waiting until the eve before charge conference! By that point, it may well be too late.

11/14/2001 - Non-Charge Preservation of Error
State Bar of Texas 24th Advanced Civil Trial Course (Nov. 14, 2001)

05/11/2000 - Federal Appellate Review of Decisions of the Trial Court Before Final Judgment on All Claims
Fifth Circuit Reporter (May 11, 2000)