Justice Devine delivered the opinion of the Court. This case presents two issues: first, whether an affirmative defense may be the basis of a Rule 91a motion to dismiss; and second, whether the alleged destruction of evidence is an action "taken in connection with representing a client in litigation," thus entitling the respondent attorneys to attorney immunity. We join the court of appeals in concluding that Rule 91a permits dismissal based on an affirmative defense. See 581 S.W.3d 306,...