Court Discusses Establishing Causation in Texas Car Accident Cases

Car accidents are common throughout Texas, often causing substantial injuries. People involved in collisions will often pursue damages from the responsible parties. As discussed in a recent Texas car accident case, Varavoot Anantasomboon v. Ashley Waggoner (No. 05-23-00390-CV), even if a plaintiff proves a defendant’s negligence caused a crash, they will not be rewarded damages unless they also demonstrate causation. If you sustained injuries in a car accident, it is critical to retain a Texas car accident lawyer to help you fight to protect your interests.

History of the Case

It is reported that the plaintiff and defendant were involved in an automobile accident in July 2019. The plaintiff subsequently filed a negligence suit against the defendant, seeking damages for alleged neck, back, and shoulder injuries. The trial took place in January 2023; the jury found that the defendant’s negligence caused the accident. When asked about compensating the plaintiff for medical expenses, past and future pain, and suffering, the jury awarded zero damages in all categories. Consequently, the trial court entered a judgment awarding the plaintiff zero damages and allowing the defendant to recover her costs from the plaintiff.

Allegedly, the plaintiff filed a motion to modify the judgment and for a new trial, arguing that the jury’s zero-damages verdict was against the overwhelming evidence and manifestly unjust, considering his medical expenses exceeded $30,000. The plaintiff also contended that the defendant should not have been awarded costs since he prevailed on the negligence question. After the trial court denied his motion, the plaintiff appealed.

Establishing Causation in Texas Car Accident Cases

On appeal, the plaintiff argued that the trial court erred by not setting aside the jury’s zero-damages verdict despite substantial evidence of his medical expenses and suffering. The court disagreed, ultimately upholding the trial court ruling.

Specifically, the court explained that the evidence showed that the plaintiff experienced pain following the accident, sought chiropractic treatment, and was eventually diagnosed with bulged discs pinching a nerve. He admitted to previous symptoms of tingling fingers and an unrelated diagnosis of tennis elbow, however, suggesting some preexisting conditions. Additionally, conflicting medical opinions were presented regarding the cause of his injuries, with some attributing them to the accident and others not.

Further, the court noted that despite the plaintiff’s affidavits proving the reasonableness and necessity of his medical expenses, these affidavits did not establish causation of the injuries. The jury instructions emphasized excluding any conditions not resulting from the accident or preexisting conditions not aggravated by it.

Given the subjective nature of the plaintiff’s pain, the lack of immediate objective injuries, and conflicting evidence about the cause and extent of his injuries, the court concluded that the jury’s zero-damages finding was not manifestly unjust. The court upheld the jury’s verdict, ruling that the plaintiff’s evidence did not sufficiently establish that his injuries were caused by the accident. As such, the court affirmed the trial court’s judgment.

Meet with a Trusted Texas Car Accident Attorney

If you were hurt in a car crash caused by another driver’s recklessness, you may be able to recover damages in a civil lawsuit, and it is smart to meet with an attorney. Earl Drott is a trusted Texas car accident attorney who is proficient at helping car accident victims seek justice, and if you hire him, he will advocate zealously on your behalf. You can contact Mr. Drott to arrange a free consultation through the online form or by calling 903-531-9300.

Contact Information