Harris County v. Smith
The Smiths were injured in a 1994 automobile collision with Deputy Sheriff Spurgeon. A jury found Spurgeon's negligence caused the injuries and awarded the Smiths $95,100 in damages. Harris County appealed, challenging the inclusion of 'loss of earning capacity' for Lynn Smith and 'physical impairment' for Erica Smith in the broad-form damages question, arguing insufficient evidence. The appellate court agreed that the trial court erred in submitting these specific elements due to lack of evidence. However, it concluded that traditional harm analysis, rather than the 'presumed harm' standard from Crown Life Insurance Co. v. Casteel, applied to erroneously submitted elements of a broad-form damages question. Applying traditional harm analysis, the court found sufficient evidence to support the overall damages awarded to Lynn Smith for medical care, physical pain, and mental anguish, and to Erica Smith for medical care, physical pain, and mental anguish, rendering the errors in submitting the unsupported elements non-reversible. The judgment of the trial court was affirmed.