Harris County, Texas, Petitioner v. Lynn Smith, Erica Smith

Summary

The Texas Supreme Court held that the trial court's broad‑form damage questions, which included elements lacking evidentiary support, constituted harmful error requiring reversal and remand. The Court applied the reasoning of Crown Life Insurance Co. v. Casteel to damage questions, finding that the error prevented Harris County from presenting its case on appeal. Justice O’Neill dissented, arguing the error was harmless. The decision reaffirms the harmful‑error standard for broad‑form submissions.