Wal-Mart Stores, Inc. v. Redding

WITTIG, Justice,

dissenting.

Because the majority opinion incorrectly applies the recent supreme court holding in Casteel, I respectfully dissent. My brothers unintentionally compound and confound the confusion of court charge practice in Texas. Trials courts are mandated by Rule 277 to use broad form submission to all aspects of the court’s charge, wherever feasible. Tex.R. Civ. P. 277. In fact, failure to use broad form damage questions can produce reversible (harmful) error. Westgate Ltd. v. State, 843 S.W.2d 448, 458 (Tex.1992); cf. H.E. Butt Grocery v. Warner, 845 S.W.2d 258, 260 (Tex.1992). Rather than take a more studied, judicially restrained approach to the rules of charge practice, the opinion rushes to extend a narrow holding into an exception that swallows the rule. The opinion is erroneous in several particulars.

Waiver — The Charge Conference

At the charge conference, Wal-Mart did not object to the court’s charge on the basis of broad form submission. The trial court is mandated to submit controlling questions of liability and damages in broad form and has no discretion to do otherwise. Missouri Pacific R. Co. v. Lemon, 861 S.W.2d 501 (Tex.App.—Houston [14th Dist] 1993, writ dism’d by agr.). Therefore, it is particularly incumbent upon an objecting party to point out to the trial court that broad form submission is not feasible, and why broad form submission is not feasible. Tex.R. Civ. P. 274; see also Crundwell v. Becker, 981 S.W.2d 880, 884 (Tex.App.—Houston [1st Dist.] 1998, pet. denied). In the charge conference, Wal-Mart objected to both the liability and allocation questions on the basis of “no evidence of any negligence ” even though the second question dealt with percentages. Wal-Mart claims it objected to the broad form damage question with a rambling soliloquy about medical care, deposition testimony, Dr. Lionberger, MRI, and the stipulation to $5,906 medicals paid “doesn’t make them reasonable and necessary “Second, [still discussing question 3, the damages] with regard to the, I guess, lack of breakdown for the damages on Question No. 3 and a specific amount for both — for physical pain, physical impairment, and medical care, we object that those items are not broken down further.” The question was presented right out of the pattern jury charge book, with separate elements, including physical pain, physical impairment and medical care, broken down with two answer blanks for past and future damages in the required broad form.

First, Wal-Mart did not object to the broad form submission.1 There was no *157indication to the trial judge — who had a jury in the box — that appellant thought broad form submission was not feasible. Indeed, if a common slip and fall case cannot be submitted in broad form, what case can be? Next, Wal-Mart gave no indication to the trial judge how or why the damages should be “broken down further.” While it’s been some time since I studied probability and statistics, we have three elements in two sets of possibilities. Therefore there are at least 36 differing ways to “break down further” the proper broad form question.2 The way the objection is phrased could even admit the possibility Wal-Mart wanted physical pain broken down to include mental anguish or physical impairment broken down to include disfigurement. Third, the confusing objection to “both” thereafter continues with a rambling objection and conversation about the stipulated medical damages and how the credit would be applied. In sum, Wal-Mart ‘Vas required to point out distinctly the matter to which he objected and the ground of his objection” and therefore waived any error on that ground. Davis v. Campbell, 572 S.W.2d 660, 663 (Tex.1978) (internal citations omitted); Tex.R. Crv. P. 274; Casteel, 22 S.W.3d at 389 (requiring objection to the timely and specific).

Waiver — On Appeal

First, it is well established that issues raised on appeal “must conform to those made at trial or they are waived.” Knoll v. Neblett, 966 S.W.2d 622, 639 (Tex.App.—Houston [14th Dist.] 1998, pet. denied); see also Tex.R.App. P. 33.1(a)(l)(A)(complaint to trial court must be with sufficient specificity to make trial court aware unless apparent from context). It has already been demonstrated that appellant’s complaint on appeal, broad form submission, was not made at trial. Nor was there sufficient specificity to make the trial court aware of the grounds asserted on appeal.

In addition, the Texas Supreme Court has taken the position that appellant must argue that the evidence considered as a whole is legally insufficient to support the damage findings, failing which, a no evidence challenge is to be rejected. Thomas v. Oldham, 895 S.W.2d 352, 360 (Tex.1995). While Wal-Mart on appeal does globally attack the legal and factual sufficiency of the evidence on the future physical pain and physical impairment elements, as well as future medical, it cites only contrary authority3 for its argument and, once again, has waived any error Tex.R.App. P. *15838.1(h). Wal-Mart made no factual sufficiency complaint .to the trial court. In any event the record provides amply evidence of future damages, including expert medical opinion.

Why Casteel Does Not Apply

Casteel addresses compound, complex, valid and invalid, liability theories. Casteel 22 S.W.3d at 387. Not simple, valid damage theories. See id. Four invalid DTPA liability theories were commingled amongst thirteen liability claims in a broad form submission. Id. The high court cited as precedent, Lancaster v. Fitch, 112 Tex. 293, 246 S.W. 1015 (1923). Putting aside the myriad of changes in the law since 1923, at its core Lancaster, like Casteel, finds harmful error when an invalid liability theory was submitted. Id. at 1016. Neither case is based upon legal or factual sufficiency of a valid theory of recovery. Critical to the Lancaster holding was the supreme court’s reasoning:

Under the court’s charge and under their oaths as jurors they were required to be governed by the charge. In order to hold the error harmless in the submission of the erroneous charge, we must hold that the jury disregarded the charge of the court. This we cannot do, but must presume that the jury in reaching its verdict gave full credit to this instruction and was governed by it.

Id. An altogether different situation is presented when a valid liability or damage instruction is given the jury. The jury is instructed to find, by a preponderance of the evidence, liability or damages. The valid theory of damages, such as future medical, cannot be found by the jury, except in conformity to the legally correct charge. And more importantly, the jury cannot find future medical or any other element, unless there is evidence of the future medical or other element. To hold otherwise, “we must hold the jury disregarded the charge of the court. This we cannot do, but must presume that the jury in reaching its verdict gave full credit to this instruction [find by evidence] and was governed by it.” Id.

Several courts, including Tyler, Beaumont, and Houston First Court of Appeals recently reached this result, although with some variation in reasoning. Brookshire Bros., Inc. v. Wagnon, 979 S.W.2d 343, 352-53, (Tex.App.—Tyler, 1998, no pet.), (holding broad form submission is a non-discretionary directive to trial court and harmless error where no showing jury actually awarded future medical expense in broad form damage submission); Harris County v. Smith, No. 01-99-00729-CV, 2001 WL 328164 (Tex.App.—Houston [1st Dist.] April 5, 2001, no pet. h.)(holding where key or controlling issues of liability could not be basis of jury findings, traditional harm analysis applied to no-evidence damage element);4 and Wal-Mart v. Ard, 991 S.W.2d 518 (Tex.App.—Beaumont 1999, pet. denied)(holding single element of damage in broad form question is not reviewed where appellant failed to challenge all elements; court reviews aggregate evidence (traditional harm analysis)). I note all these cases have some valid theories of liability and damages. Even this court has previously held that under broad form submission, appellant must demonstrate that none of the grounds he relies upon by jury support the verdict. Lemon, 861 S.W.2d at 532.

*159I join Justice Taft’s implicit criticism of Casteel.5 Casteel changes the burden of showing harm on appeal from the appellant to the appellee. A test of “might have effected” versus “probably effected” is as different as floating downstream versus swimming upstream. Because Casteel must be read in connection with Thomas, Island Recreational, 710 S.W.2d at 555, and E.B., 802 S.W.2d at 649, it should be viewed and applied narrowly and consistently with Rules 277 and 274. In sum, I would apply the Casteel holding only when an invalid theory of law or damages is given to the jury. Lack of legal or factual sufficiency is not an invalid theory of law but rather a valid theory that is unsupported by the evidence. For example, when, like Casteel, four invalid, non-recoverable, theories are submitted globally, and the jury in following their instructions could answer a key or controlling issue adversely, then, harm under TRAP 44.1(a)(2) would be shown. Ordinarily, however, appellant, not appellee, must demonstrate harm. When a legally recognized theory of liability or damages is presented to the jury, appellant must show none of the grounds relied upon by the jury support a jury answer. Lemon, 861 S.W.2d at 532; Smith, 2001 WL 328164, at *6. To do otherwise encourages the para-logical paradox of harmful error in granulating questions instead of submitting the required broad-form. See Exxon Pipeline v. Zwahr, 35 S.W.3d 705, 713 (Tex.App.—Houston [1st Dist.] 2000, no pet. h.)(submitting two questions of damages instead of one is harmful error).

I would affirm the judgment of the trial court.

. The majority opinion ignores Wal-Mart's citation to the record at CR 214 for its basis in challenging the broad form submission. Instead, the majority scours the record to find its own basis to support appellant’s impoverished position. While Wal-Mart did object later in the charge conference on the basis of “no evidence” to the future medical expenses, the trial court did not rule on this objection. Even assuming the trial court appreciated the no-evidence objection and implicitly overruled it, appellant did not object to the broad form submission or state why it was non-feasible. Further, appellant did not, at any juncture, raise factual sufficiency, though each of its appellate issues speak of legal and *157factual sufficiency. For at least some semblance of a reasonable objection pointing out distinctly the grounds and the reason, see Smith at n. 2.

. Nominating past damages as A, B and C and future damages as D, E. and F, we could have A in one question, B C another, D, another, and E F another. Or perhaps Wal-Mart meant AB should “both” be submitted together, then C, then DE, and then F. Et cetera. While I believe the trial court in this case was presented with some evidence of future medical, see Strahan v. Davis, 872 S.W.2d 828, 832 (Tex.App.—Waco 1994, writ denied), appellee’s counsel conceded there was no evidence of future medical. Thus both the majority and dissent assume no evidence of future medical. I would note, however, that if there is a serious sufficiency or pleading objection to any part of the charge, or if there is a serious question concerning legal validity of a recovery theory, the better practice would be to segregate that element to obviate these esoteric musings. Counsel’s objections, as here, should not be rambling, multifarious generalities complaining of everything. Rather the rule clearly requires the objection to both distinctly point out the objectionable matter and state the grounds of the objection. Tex.R. Civ. P. 274.

. Appellant cites Wal-Mart Stores, Inc. v. Ard, 991 S.W.2d 518 (Tex.App. — Beaumont 1999, pet. denied).

. I note Justice Taft's well reasoned and vitally correct opinion uses the word "erroneous” instead of the supreme court’s language “invalid theory.” A jury submission may be erroneous but not an invalid theory. He seems to define his logic more in terms of key and controlling issues. Quite obviously I agree an invalid theory would typically be a key or controlling issue.

. An old adage states those who do not learn from history, aré doomed to repeat it. It dates me to recall the old granulated special issue practice. Most of the bench and bar today grew up past that era. Under the old special issue practice, a simple car wreck case would have 35 to 45 issues typically: (1) Did defendant fail to keep a look out? (2) Was such failure to keep a look out negligence? (3) Was such negligence a proximate cause of the accident? (4) Was plaintiff damaged as a result of the negligence of defendant? Then, in sequence, multiple questions were presented about application of brakes, yielding right of way, speed, swerving to avoid accident, etc., etc., to then be followed by granulated damage questions. Jurors and parties were made to wait hours, or even days, to arrive at a technically correct charge. I had an entire file cabinet filed with thousands of special issues, one for each shade of difference in the submission. Neither justice nor the jury system were served by this arcane special issue practice. To return to anything like that practice now is truly reactionary. Even the submission of a simple “negligence” or "fail to perform the contract” question subsumes multiple elements. Accordingly, only when an entire theory of recovery is invalid, as was the case in Casteel, would broad form not be feasible. Or to paraphrase the words of Justice Taft, only when a key or controlling question is invalid, would broad form not be feasible.