Texas Supreme Court
L. D. Ormsby v. R. E. Ratcliffe
January 11, 1928117 Tex. 242
Summary
The Texas Supreme Court held that Texas Art. 2190 permits a court to deem an unsubmitted issue as found only when it is supplemental to issues submitted to the jury and supports the judgment; independent causes of action or defenses that are not submitted are waived. The Court refused the writ of error, thereby affirming the Court of Civil Appeals' judgment.