Texas Supreme Court
Wichita Falls & Oklahoma Railway Company v. A. C. Pepper
January 10, 1940134 Tex. 360
Summary
The Texas Supreme Court affirmed the Court of Civil Appeals' judgment, holding that under Art. 2190 a trial court may make findings on unsubmitted, unrequested issues that are supplemental to the jury's ultimate finding, provided there is evidence to support those findings, but it may not base judgment on independent grounds of recovery or defense that were omitted.