Christus Health Gulf Coast D/B/A Christus St John Hospital v. Jay Houston, 01-14-00399-CV

This is a Texas medical malpractice appeal from the First District Court, involving Christus Health Gulf Coast and a vascular complication following shoulder surgery.
Houston alleges the surgeon breached the standard of care by not immediately calling a vascular surgeon and by post-operative management failures leading to nerve and muscle injury.
Holt allegedly injured the axillary artery during surgery, causing substantial blood loss and later ischemia to Houston's left arm; nerves were damaged.</n>
Houston settled with Holt prior to trial; the remaining claim at trial was against Christus nurses for post-surgery negligence.
Christus designated Dr. Gomez as trial expert; the trial court allowed him to testify about immediate vascular breach but excluded causation timing (original surgery vs. post-operative care); portions of his deposition were later played for the jury.
The jury found Holt 40% and Christus 60% liable, awarding total damages of $1,610,000; post-trial, the court reduced damages first to $1,427,826.76, then to $1,180,000, prompting Christus’s appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Gomez testimony	Gomez was qualified and his timing opinion mattered.	The court should have allowed the full causation timing opinion.	Court did not abuse discretion; excluded part because not reliably linkable to damages.
Settlement credits and damages cap calculation	Edinburgh requires applying settlement credits before cap; proportionate approach is incorrect.	Credit should be applied after or in a way that preserves the cap for non-economic damages.	Settlement credits apply first; modify damages to reflect proportionate credit, resulting in $1,122,813.66 total.
Prejudgment interest on past damages			Trial court’s prejudgment interest calculation approved; interest on total past damages is proper; dates and rate correct.
Periodic payments for future damages			Trial court properly exercised discretion to order immediate payment of part and periodic payments for future medical expenses; other future damages discretionary.

E.I. du Pont de Nemours & Co. v. Robinson, 923 S.W.2d 549 (Tex. 1995) (establishes Rule 702 standard for expert admissibility)
Gammill v. Jack Williams Chevrolet, Inc., 972 S.W.2d 713 (Tex. 1998) (gatekeeping and reliability of expert testimony)
Exxon Pipeline Co. v. Zwahr, 88 S.W.3d 623 (Tex. 2002) (relevance and foundation of expert testimony)
Helena Chem. Co. v. Wilkins, 47 S.W.3d 486 (Tex. 2001) (reliability standards for expert testimony outside courtroom)
Merrell Dow Pharm., Inc. v. Havner, 953 S.W.2d 706 (Tex. 1997) (reliability of medical expert testimony)
Edinburgh Hospital Authority v. Trevino, 941 S.W.2d 76 (Tex. 1997) (settlement credits applied before statutory damages cap)
Chesser v. LifeCare Mgmt. Servs. L.L.C., 356 S.W.3d 613 (Tex. App.—Fort Worth 2011) (prejudgment interest not part of noneconomic damages cap; discretion on fees)