James Bowman v. Mitulkumar Patel

CourtCourt of Appeals of Texas
DecidedFebruary 16, 2012
Docket01-10-00811-CV
StatusPublished

This text of James Bowman v. Mitulkumar Patel (James Bowman v. Mitulkumar Patel) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Bowman v. Mitulkumar Patel, (Tex. Ct. App. 2012).

Opinion

Opinion issued February 16, 2012.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-10-00811-CV

———————————

James g. bowman, Appellant

V.

mitulkumar patel, Appellee

On Appeal from the 127nd District Court

Harris County, Texas

Trial Court Case No. 08CV21953

MEMORANDUM OPINION

In a negligence action, a jury found appellant, James G. Bowman, to have caused a two car accident with appellee, Mitulkumar Patel. The jury awarded Patel $3,000 for past physical pain, $6,032 for past medical care, and $5,000 for past mental anguish. In four issues, Bowman challenges the trial court’s judgment, contending that (1) there was legally and factually insufficient evidence to support an award for past mental anguish; (2) the trial court wrongfully excluded evidence of Patel’s work record; (3) opposing counsel presented an improper jury argument regarding attorney’s fees; and (4) if no single error warrants a new trial, the cumulative effect of these errors does. We reverse and render in part and reverse and remand in part.

BACKGROUND

Patel filed suit in Harris County, Texas alleging that Bowman was negligent and that his acts were the proximate cause of a car accident between the two drivers. At trial, Patel testified about the accident and Bowman’s involvement in the rear-end collision. Bowman also testified, conceding that he caused the accident.  After the accident, Patel was taken to Montgomery County Medical Center by EMS, where he was treated for neck and back pain, and then released later the same day. Patel was given a prescription and also received treatments from a chiropractor for his neck and back pain. However, Patel never followed up with a specialist or any other medical doctor, and never underwent surgery for his injuries.

     After closing arguments, the jury returned a verdict in favor of Patel. Bowman then filed a motion for a new trial concerning, among other things, the award for mental anguish, the exclusion of evidence of Patel’s work history, and Patel’s closing argument referencing attorney’s fees. The motion was denied, and this appeal followed.

SUFFICIENCY OF THE EVIDENCE

In his first issue, Bowman contends the evidence presented at trial was legally and/or factually insufficient to show past mental anguish. Bowman argues Patel offered nothing during his testimony to show mental anguish, and that the record contains no evidence of past mental pain or distress. 

Standard of Review

An award of compensatory damages for mental anguish will survive a legal sufficiency challenge if the record contains direct evidence of the nature, duration, and severity of the plaintiff’s mental anguish, thus establishing a substantial disruption in the plaintiff’s routine. Parkway Co. v. Woodruff, 901 S.W.2d 434, 444 (Tex. 1995). If claimants fail to present direct evidence of the nature, duration, and severity of their anguish, the appellate court conducts a traditional no-evidence review. Id. In this review, the court determines whether the record contains any evidence of a high degree of mental pain and distress that is more than mere worry, anxiety, vexation, embarrassment, or anger. Id. We note, however, that the absence of evidence of the nature, duration, and severity of mental anguish, particularly when it can be readily supplied or procured by the plaintiff, justifies close judicial scrutiny of other evidence offered on this element of damages. Id.  A plaintiff may recover for mental anguish after providing evidence of “a mental sensation of pain resulting from such painful emotions as grief, severe disappointment, indignation, wounded pride, shame, despair or public humiliation or a combination of any of these.” Wal–Mart Stores, Inc. v. Odem, 929 S.W.2d 513, 528 (Tex. App.—San Antonio 1996, writ denied). However, evidence that a plaintiff “was unable to sleep, was depressed, and suffered from anxiety . . . does not rise to the level of compensable mental anguish as defined by Texas law.” Lefton v. Griffith, 136 S.W.3d 271, 279 (Tex. App.—San Antonio 2004, no pet.) (citation and quotations omitted); see also Saenz v. Fid. & Guar. Ins. Underwriters, 925 S.W.2d 607, 614 (Tex. 1996) (explaining that, though plaintiff's concerns were both “real” and “understandable,” they were not compensable under Texas law).

Evidence of Mental Anguish

Bowman contends Patel offered no evidence to support his claim for mental anguish. He claims Patel presented only evidence of physical suffering, but not of mental or emotional distress. However, Patel insists his continuous headaches and lack of concentration, which affected his work, are proof of his mental anguish.

Here, Patel presented evidence only to his physical pain, and the record is absent of any direct evidence to the nature, duration, and severity of his mental anguish. Patel testified to continuous headaches, in addition to his back and neck pains. He complained the headaches affected his concentration, and that he could not work. All of his physical ailments, with the exception of occasional headaches, had resolved by the time of trial.  Patel provided no testimony regarding the emotional effects of his injury. He never saw a psychiatrist or psychologist.

Because the jury provided separate awards for physical pain and mental anguish, evidence of Patel’s physical pain is not relevant to an award for mental anguish. See Rice Food Mkts., Inc. v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Living Centers of Texas, Inc. v. Penalver
256 S.W.3d 678 (Texas Supreme Court, 2008)
Phillips v. Bramlett
288 S.W.3d 876 (Texas Supreme Court, 2009)
Texas Mutual Insurance Co. v. Ruttiger
265 S.W.3d 651 (Court of Appeals of Texas, 2008)
Gunn Infiniti, Inc. v. O'BYRNE
996 S.W.2d 854 (Texas Supreme Court, 1999)
Mentis v. Barnard
870 S.W.2d 14 (Texas Supreme Court, 1994)
Wal-Mart Stores, Inc. v. Odem
929 S.W.2d 513 (Court of Appeals of Texas, 1996)
Chance v. Chance
911 S.W.2d 40 (Court of Appeals of Texas, 1995)
Town East Ford Sales, Inc. v. Gray
730 S.W.2d 796 (Court of Appeals of Texas, 1987)
University of Texas at Austin v. Hinton
822 S.W.2d 197 (Court of Appeals of Texas, 1992)
Saenz v. Fidelity & Guaranty Insurance Underwriters
925 S.W.2d 607 (Texas Supreme Court, 1996)
Gee v. Liberty Mutual Fire Insurance Co.
765 S.W.2d 394 (Texas Supreme Court, 1989)
McCraw v. Maris
828 S.W.2d 756 (Texas Supreme Court, 1992)
Lefton v. Griffith
136 S.W.3d 271 (Court of Appeals of Texas, 2004)
Austin v. Weems
337 S.W.3d 415 (Court of Appeals of Texas, 2011)
Fletcher v. Minnesota Mining & Manufacturing Co.
57 S.W.3d 602 (Court of Appeals of Texas, 2001)
Parkway Co. v. Woodruff
901 S.W.2d 434 (Texas Supreme Court, 1995)
Gulf Liquids New River Project, LLC v. Gulsby Engineering, Inc.
356 S.W.3d 54 (Court of Appeals of Texas, 2011)
Sproles Motor Freight Lines, Inc. v. Long
168 S.W.2d 642 (Texas Supreme Court, 1943)
Rice Food Markets, Inc. v. Williams
47 S.W.3d 734 (Court of Appeals of Texas, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
James Bowman v. Mitulkumar Patel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-bowman-v-mitulkumar-patel-texapp-2012.