Oscar Luis Lopez v. LA MADELEINE OF TEXAS
This case involves an appeal by Oscar Luis Lopez against La Madeleine of Texas, Inc., following a personal injury lawsuit where Lopez alleged negligence. During the trial, La Madeleine introduced a surveillance videotape and photos to impeach Lopez's testimony about his injuries, despite intentionally failing to disclose this evidence during discovery. The trial court admitted the evidence, leading to a jury finding of no negligence against La Madeleine. On appeal, the Court of Appeals of Texas, Dallas, reversed the trial court's final judgment, ruling that the admission of the undisclosed evidence was an abuse of discretion under Texas Rule of Civil Procedure 193.6, which mandates exclusion without good cause or lack of unfair surprise/prejudice. The court found La Madeleine failed to meet its burden and the error probably caused an improper judgment. However, the appellate court affirmed the denial of Lopez's motion for monetary sanctions. The case was remanded for further proceedings.