Steak & Ale of Texas, Inc. v. Borneman
This is a dram shop case on remand from the supreme court, which had agreed that a previous jury charge was erroneous but directed a new trial instead of a rendered judgment. The current opinion addresses several points not previously considered. The court found that the evidence was legally sufficient to support the jury's liability finding against Bennigan's for serving an obviously intoxicated individual. However, the court sustained Bennigan's complaint regarding an erroneous jury instruction that misstated the law concerning the Dram Shop Act. Most significantly, the court concluded that exemplary or punitive damages are not recoverable under the Texas Dram Shop Act, as the Act is an exclusive remedy providing only for compensatory damages. Therefore, the trial court's judgment is reversed, and the case is remanded for a new trial.