Phyllis Litchenburg, and Jack Litchenburg v. Conmed Corporation (a/K/A ConMed Aspen Labs)

CourtCourt of Appeals of Texas
DecidedMarch 6, 2008
Docket01-07-00230-CV
StatusPublished

This text of Phyllis Litchenburg, and Jack Litchenburg v. Conmed Corporation (a/K/A ConMed Aspen Labs) (Phyllis Litchenburg, and Jack Litchenburg v. Conmed Corporation (a/K/A ConMed Aspen Labs)) 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
Phyllis Litchenburg, and Jack Litchenburg v. Conmed Corporation (a/K/A ConMed Aspen Labs), (Tex. Ct. App. 2008).

Opinion

Opinion Issued March 6, 2008

Opinion Issued March 6, 2008



In The

Court of Appeals

For The

First District of Texas


NO. 01-07-00230-CV


PHYLLIS LITCHENBURG AND JACK LITCHENBURG, Appellants

V.

CONMED CORPORATION (a/k/a CONMED LABS), Appellee


On Appeal from the 80th District Court

Harris County, Texas

Trial Court Cause No. 2005-34760



MEMORANDUM OPINION

          Phyllis and Jack Litchenburg brought a product liability suit against ConMed Corporation for injuries Mrs. Litchenburg suffered during surgery.  After striking the Litchenburgs’ expert, the trial court granted ConMed’s no-evidence summary judgment motion.  On appeal, the Litchenburgs’ contend that the trial court erred by: (1) striking their expert witness; (2) granting ConMed’s no-evidence summary judgment motion; (3) excluding certain summary judgment evidence; and (4) awarding court costs to ConMed.  We affirm.

Background

          In November 2003, Phyllis Litchenburg underwent a bilateral breast reduction surgery.  During a follow-up appointment the day after the surgery, the doctor noticed a blister on Mrs. Litchenburg’s back, approximately two and a half to three inches wide.  In early January 2004, Mrs. Litchenburg’s surgeon cleaned and treated the wound, which had grown severe.  The doctor told the Litchenburgs that he believed the wound was an electrical burn caused by a grounding pad, used during her surgery.  By late March, the wound had healed, but left a scar.  The Litchenburgs contend that the burn was caused by an electrical defect in an instrument that ConMed manufactured.

          In May 2005, the Litchenburgs sued the doctor who performed the surgery and the hospital, but voluntarily non-suited both after joining ConMed to the suit in December 2005.  The trial court’s docket control order required the Litchenburgs to disclose their experts by July 7, 2006.  On that day, the Litchenburgs designated a professional engineer as their products liability expert, but did not provide the expert’s opinion and materials, as required by Rule 194.2(f).  Tex. R. Civ. P. 194.2(f).  ConMed moved to strike the Litchenburgs’ expert, contending that their expert witness designation did not comply with the disclosure requirements.  On September 14, 2006, rather than striking the expert, the trial court granted the Litchenburgs additional time to supplement their disclosure responses.  The court also required them to produce their expert, Mr. Daken, for deposition within three weeks—trial having been set for November 6th—and pay $1000 in attorney’s fees.

          The Litchenburgs supplemented their discovery responses and paid the sanction.  They did not, however, present Mr. Daken for deposition within the trial court’s three-week deadline.  After inquiry from opposing counsel, the Litchenburgs offered deposition dates in late October, past the court’s deadline.  ConMed then filed a second motion to strike as a result of the Litchenburgs’ failure to comply with the court’s order.  On November 6, 2006, the date of the initial trial setting, the trial court granted ConMed’s second motion and excluded Daken as an expert witness.

          In December 2006, ConMed moved for no-evidence summary judgment.  Subsequently, noting that the trial setting had passed, the Litchenburgs moved to vacate the court’s November 6th order and filed a response to the summary judgment motion.  ConMed objected to certain evidence that the Litchenburgs included in their response, which the trial court sustained.  The trial court granted summary judgment on February 23, 2007, and denied the Litchenburgs’ motion to vacate its order striking their expert. 

Striking of Expert Witness

          In their first issue, the Litchenburgs contend that the trial court erred in striking their expert witness because the court’s discovery sanctions do not survive the resetting of trial.  Alternatively, they assert that the trial court erred in striking their expert witness because the discovery sanctions amounted to a death penalty sanction far greater than necessary to punish, without a direct nexus between the offensive conduct and the sanctions imposed.

Resetting of trial

A party must designate experts by furnishing the information requested under Rule 194.2(f) by the later of thirty days after the request is served, or with regard to all experts testifying for a party seeking affirmative relief, ninety days before the end of the discovery period.  Tex. R. Civ. P. 195.2.  If a party fails to do so, then that witness may not testify at trial without a showing of good cause or unfair surprise.  Rule 193 provides:

(a) Exclusion of Evidence and Exceptions. A party who fails to make, amend, or supplement a discovery response in a timely manner may not introduce in evidence the material or information that was not timely disclosed, or offer the testimony of a witness (other than a named party) who was not timely identified, unless the court finds that:

(1) there was good cause for the failure to timely make, amend, or supplement the discovery response; or

(2) the failure to timely make, amend, or supplement the discovery response will not unfairly surprise or unfairly prejudice the other parties.

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