Amazon.com Services, LLC v. Jessica G. Holguin

CourtTexas Court of Appeals, 8th District (El Paso)
DecidedMay 5, 2026
Docket08-25-00086-CV
StatusPublished

This text of Amazon.com Services, LLC v. Jessica G. Holguin (Amazon.com Services, LLC v. Jessica G. Holguin) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 8th District (El Paso) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amazon.com Services, LLC v. Jessica G. Holguin, (Tex. Ct. App. 2026).

Opinion

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS ————————————

No. 08-25-00086-CV ————————————

Amazon.com Services, LLC, Appellant

v.

Jessica G. Holguin, Appellee

On Appeal from the 346th District Court El Paso County, Texas Trial Court No. 2024DCV0485

M E MO RA N D UM O PI NI O N

Appellant Amazon Services, LLC filed this restricted appeal of the default judgment

entered in favor of Appellee Jessica G. Holguin. We affirm in part and reverse in part.

I. BACKGROUND

Holguin sued Amazon, her employer, for injuries she sustained moving heavy items at

work. Amazon did not file an answer or otherwise appear. Holguin filed a motion for entry of a default judgment, and the trial court held a hearing on unliquidated damages. Holguin’s testimony,

the only evidence presented, spans less than seven pages of the record and consists mostly of the

answer “yes” to her attorney’s leading questions. 1 Both before and after the hearing, Holguin filed

with the clerk notices of intent to use business records with attached business records affidavits

from her medical providers. 2 The affidavits were not submitted in support of Holguin’s motion for

default judgment or admitted into evidence.

After the default hearing, the trial court awarded Holguin the following damages, totaling

$997,749.55:

Past medical expenses $60,000 Future medical expenses $240,000 Past physical pain and mental anguish $100,000 Future physical pain and mental anguish $150,000 Past loss of earning capacity $4,650.00 Future loss of earning capacity $116,064.00 Past disfigurement $10,000 Future disfigurement $10,000 Past physical impairment $100,000 Future physical impairment $200,000 Prejudgment interest $7,035.55

Amazon filed this restricted appeal raising one issue: whether the evidence was legally and

factually sufficient to support the amount of damages. 3 We discuss each category of damages and

the evidence presented.

1 The only non-yes answers that Holguin gave were her date of birth and her position at Amazon. 2 The medical records themselves were not filed. 3 In her response brief, Holguin asserts that there is no error because Amazon was properly served with citation. Amazon does not argue any error in service.

2 II. ANALYSIS

A. Restricted appeal

To prevail in a restricted appeal, an appellant must establish that: (1) the notice of restricted

appeal was filed within six months after the judgment was signed; (2) it was a party to the

underlying lawsuit; (3) it did not participate in the hearing that resulted in the judgment complained

of and did not timely file any post-judgment motions or requests for findings of fact and

conclusions of law; and (4) error is apparent on the face of the record. Alexander v. Lynda’s

Boutique, 134 S.W.3d 845, 848 (Tex. 2004); Tex. R. App. P. 30. The face of the record, for the

purposes of a restricted appeal, consists of all papers before the trial court when it rendered its

default judgment. Id. at 848–49.

The default judgment was signed on October 1, 2024, and Amazon filed its notice of appeal

on March 17, 2025, within six months of the judgment. Amazon did not participate in the final

hearing and did not file any post-judgment motions or requests for findings of fact or conclusions

of law. The first three elements for a restricted appeal are met. We focus our analysis on whether

Amazon has established that error is apparent on the face of the record.

B. Standard of review

When a defendant fails to answer, it admits to facts pleaded in the plaintiff’s petition except

for the amount of unliquidated damages, for which the trial court must take evidence. Holt Atherton

Indus., Inc. v. Heine, 835 S.W.2d 80, 83 (Tex. 1992); Tex. R. Civ. P. 243. Amazon challenges only

the amount of damages and not Holguin’s injury or its liability.

The sufficiency of the evidence to support damages can be reviewed in a restricted appeal

which “affords an appellant the same scope of review as an ordinary appeal[.]” Whitaker v. Rose,

218 S.W.3d 216, 220 (Tex. App.—Houston [14th Dist.] 2007, no pet.). In a legal sufficiency review

3 of a finding on which the appellant did not have the burden of proof, we must affirm a verdict

unless (1) there is “a complete absence of evidence of a vital fact,” (2) “the court is barred by rules

of law or of evidence from giving weight to the only evidence offered to prove a vital fact,” (3)

there is “no more than a mere scintilla” of evidence proving a vital fact; or (4) the evidence

conclusively establishes the opposite proposition of a plaintiff’s proffered vital fact. City of Keller

v. Wilson, 168 S.W.3d 802, 810 (Tex. 2005). In reviewing the evidence, we “must credit favorable

evidence if reasonable jurors could, and disregard contrary evidence unless reasonable jurors could

not.” Id. at 827. In a factual sufficiency review, we “consider and weigh all of the evidence, and

can set aside a verdict only if the evidence is so weak or if the finding is so against the great weight

and preponderance of the evidence that it is clearly wrong and unjust.” Dow Chem. Co. v. Francis,

46 S.W.3d 237, 242 (Tex. 2001).

C. Medical Expenses

(1) Past medical expenses

An award of damages for medical expenses must be supported by evidence of the amount

paid or incurred. Tex. Civ. Prac. & Rem. Code § 41.0105 (“recovery of medical or health care

expenses is limited to the amount actually paid or incurred by or on behalf of the claimant”). In

addition, there must be evidence that the expenses were both reasonable and necessary. In re K &

L Auto Crushers, LLC, 627 S.W.3d 239, 249–50 (Tex. 2021). The reasonable and necessary factors

can be proven either by expert testimony or an affidavit made by the provider or custodian of

records that includes an itemized statement of the charges and states that “the amount [] charged

for a service was reasonable at the time and place that the service was provided and that the service

was necessary.” Tex. Civ. Prac. & Rem. Code § 18.001 (b), (c). Jackson v. Gutierrez, 77 S.W.3d

898, 902–03 (Tex. App.—Houston [14th Dist.] 2002, no pet.).

4 At the hearing, Holguin’s attorney asked her a series of questions about the tests she

underwent and treatments she received. For example, she confirmed that she had MRIs, received

therapy and pain injections, and went to two different emergency rooms because of the pain. The

only evidence of the amount of past medical expenses was the following question and answer:

Q. Now, the medical expenses that you have from everything, is that about $16,000?
A. Yes.

Not only was the evidence at trial for a different amount than that awarded in the final judgment

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Bluebook (online)
Amazon.com Services, LLC v. Jessica G. Holguin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/amazoncom-services-llc-v-jessica-g-holguin-txctapp8-2026.