Payne Mitchell Ramsey

Shannon Hays

Shannon Hays

Shannon Hays



Shannon Hays offers proven expertise in trial and appellate litigation, in both federal and state courts. Her practice areas include appellate matters, general negligence, products liability, business torts and aviation. Over her career, Shannon has had a winning record of drafting numerous successful briefs before both federal and state trial courts and appellate courts. Prior to joining Payne Mitchell Ramsey, Shannon held positions at the law firms of Vinson & Elkins LLP and Hogan Lovells (formerly Hogan & Hartson LLP). At these firms, she represented a diverse array of clients, litigating a variety of employment claims, insurance coverage disputes, civil RICO claims, securities fraud cases, contractual disputes and other complex commercial disputes.

Her background also includes serving as a staff attorney for the United States Court of Appeals for the District of Columbia Circuit. In this capacity, she provided legal recommendations to the judges on dispositions of motions and briefs covering a broad range of matters. Her responsibilities also included drafting orders and judgments for publication.

Shannon earned a B.A. summa cum laude from Baylor University, Phi Beta Kappa, and a J.D. with honors, Order of the Coif, from The University of Texas at Austin School of Law, where she served as a member of the Texas Law Review and won the award of Best Texas Law Note in 1999.

When she’s not practicing law, Shannon enjoys spending time with her husband, three daughters and many pets. She regularly volunteers through the National Charity League with her daughters and likes to run, bake and read when she has a spare moment.

Notable Results

  • Drafted successful brief in appellate matter before the Wyoming Supreme Court, which overturned a lower court’s decision and resulted in a seven-figure settlement for the client. 
  • Drafted successful motion for new trial in a personal injury case, in which the trial court overturned its prior ruling, resulting in a substantial settlement for the client.
  • Drafted numerous successful pre-trial responses, including summary judgment responses and responses to motions to exclude experts in a complex products liability matter. During trial, Shannon drafted successful motions in limine. Post-trial, Shannon drafted successful responses to motions for judgment notwithstanding the verdict and for a new trial. The trial of this matter resulted in an extremely large multi-million-dollar verdict for the client. 
  • Drafted successful response to motion to dismiss in a complex products liability case, which led to a multi-million-dollar resolution to this case in favor of the client.  
  • Drafted successful motion to remand and argued the response to a motion for summary judgment in a catastrophic accident case, which ultimately resolved in favor of the client for millions of dollars. 
  • Argued motions and drafted successful briefs in complex, multi-party, aviation case, which resulted in a substantial settlement for client. 
  • Drafted complaint, successful responsive briefs, and mediation statement in FINRA case, which resulted in successful settlement for clients. 
  •  Drafted and argued successful response to motion for summary judgment in a catastrophic personal injury case that resulted in a substantial payment to the client. 
  • Drafted successful motions and responsive motions in a catastrophic electrocution case that ultimately resolved with a multi-million-dollar settlement for the client. 

Professional Involvement + Leadership

  • Dallas Bar Association, Referral Committee 
  • Texas Trial Lawyers Association, Membership Committee
  • Collin County Women Lawyers Association, Member
  • Dallas Mothers-in-Law, Member
  • Collin County Attorney Mothers, Member
  • Texas Law Review, Alumni Member
  • Mensa International, Member
  • Texas C-Bar Volunteer (2001) (Pro Bono Corporate Legal Services)

Publications + Speeches

  • "Ford Motor Co. v. Montana Eighth Judicial Dist. Court, 592 U.S. ___ (2021): No Minds Were Blown in the Issuing of this Opinion," Collin County Bar Association Civil Litigation and Appellate Group, 2021
  • “Advanced Products Liability Update,” drafted paper for speech delivered by Andy Payne at the Advanced Personal Injury Seminar, 2014, 2016
  • “Apathy: Who Cares?," Mensa Bulletin, 2008 
  • “ERISA Preemption of Direct Liability Claims: Texas Throws Down the Gauntlet," volume 78, Texas Law Review,  Best Texas Law Note, 1999
  •  "Policy Boot Camp: Hand to Handbook Combat," speech delivered at Vinson & Elkin’s Labor and Employment Law Seminar, June 2001 
  • “The Contingent Workforce," speech delivered and published in the Labor and Employment Law Seminar presented by Lorman Education Services, October 2001
  •  “Texas Wage and Hour Update," speech delivered and published in the Wage and Hour Law Seminar presented by Lorman Education Services, December 2001


  • University of Texas, School of Law – Austin, Texas Doctor of Jurisprudence - May 2000 
    — Graduated with high honors 
    — Order of the Coif 
    — Texas Law Review 
    — Gus Macey Hodges Scholarship Recipient (1998) 
    — Robert Strauss Scholar (1997) 
  • Queen Mary and Westfield College, University of London – London, England Associate Student in the Faculty of Laws – Fall 1999, Summa Cum Laude 
    — Successfully completed courses in Juvenile Justice, European Internal Markets, Emerging Economies, and International Commercial Litigation 
    — Baylor University – Waco, Texas Bachelor of Arts, Major in English, Minor in History – May 1996 
    — Phi Beta Kappa 
    — Mortar Board Honor Society, Fundraising Chairman 
    — Pi Beta Phi, President


  • Licensed by the State Bar of Texas
  • Licensed by the District of Columbia Bar