Jorge H. Trevino, M.d. v. Genaro Ortega

Summary

The Texas Supreme Court held that Texas does not recognize an independent cause of action for intentional or negligent spoliation of evidence, reversing the Court of Appeals and entering judgment that Ortega takes nothing. The Court reasoned that spoliation causes no independent injury and is better remedied within the underlying lawsuit, and it noted that existing sanctions and procedural tools suffice.