In Re Smith, 332 S.W.3d 704

Boyd sued Smith for property damage from a car collision; the jury found Boyd’s negligence proximately caused the accident in a broad-form question.
The trial court entered a take-nothing judgment, then granted Boyd’s motion for a new trial without stating a reason.
Smith sought mandamus to require the trial court to specify its reasons for the new-trial grant; an amended order later stated the reason as the verdict was contrary to the great weight and preponderance of the evidence.
Smith filed a new mandamus petition alleging four points of error: lack of support for the new-trial grant, erroneous reasons, inadequate remedy on appeal, and deprivation of the jury-trial right.
The court denied mandamus, holding there was no clear abuse of discretion in granting the new trial.
The court emphasized trial court discretion under Rule 320 and Columbia’s requirement for a transparent, reasonably specific explanation for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus is proper to review the trial court’s reasons for a new trial.	Smith argues Columbia/Lufkin authorize merits review of grounds.	Boyd argues mandamus only requires transparency, not merits review.	No clear abuse; no merits review required.
Whether the trial court abused its discretion in granting a new trial.	Smith contends grounds lack support or are implausible.	Court identified reasons tied to weight of evidence.	No clear abuse; order satisfies Columbia standards.
Whether Columbia/Lufkin require appellate merits review of the stated grounds.	Columbia/Lufkin permit merits review of grounds.	Review is limited to transparency, not sufficiency of grounds.	Columbia controls; no merit-based review in mandamus.
Whether the new-trial order satisfies Columbia’s transparency requirement.	Order does not disclose sufficient reasoning beyond abstract statement.	Order Provides specific, understandable reasons.	Order satisfies transparency; mandamus denied.

In re Columbia Medical Center of Las Colinas, Subsidiary, L.P., 290 S.W.3d 204 (Tex.2009) (mandamus to require reasoned new-trial justification; transparency goal; broad trial court discretion)
In re E.I. du Pont de Nemours & Co., 289 S.W.3d 861 (Tex.2009) (orig. proceeding; proper reasons not defined; transparency needed)
Johnson v. Fourth Court of Appeals, 700 S.W.2d 916 (Tex.1985) (limits on creating interlocutory review; jury trial protection)
Champion Int'l Corp. v. Twelfth Court of Appeals, 762 S.W.2d 898 (Tex.1988) (mandamus review limited to final judgments unless void; transparency purpose)
Lufkin Industries, Inc., 317 S.W.3d 516 (Tex.App.-Texarkana 2010) (clarified mandamus review scope; not full evidence sufficiency review; observed trial dynamics may justify new trial)