Jasmine Ricks v. Quality Carriers, Inc., 14-14-00431-CV

Ricks sued Quality Carriers and its driver (Smith) for negligence after a car collision, alleging employer liability for the driver’s conduct.
Quality served discovery; Ricks repeatedly failed to respond to discovery requests and failed to appear for noticed depositions despite multiple court orders to do so.
The trial court issued successive orders compelling discovery, imposed lesser sanctions, and warned dismissal could follow if Ricks again failed to comply.
Ricks continued noncompliance over more than two years; the court ultimately entered judgment for Quality Carriers (a "death penalty" sanction) dismissing Ricks’s claims with prejudice.
Ricks appealed, arguing the dismissal was an inappropriate and excessive discovery sanction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal with prejudice was an appropriate discovery sanction (death penalty)	Ricks argued the sanction was excessive and improper	Quality argued Ricks repeatedly and deliberately refused to comply with discovery and prior orders, justifying dismissal	Court affirmed: dismissal was not an abuse of discretion because (1) sanction related to Ricks’s conduct and (2) lesser sanctions had been tried and failed, supporting presumption claims lacked merit

TransAmerican Nat. Gas Corp. v. Powell, 811 S.W.2d 913 (Tex. 1991) (sets TransAmerican standards for just and proportional discovery sanctions and due-process limits on death-penalty sanctions)
Am. Flood Research, Inc. v. Jones, 192 S.W.3d 581 (Tex. 2006) (trial-court sanctions reviewed for abuse of discretion)
Cire v. Cummings, 134 S.W.3d 835 (Tex. 2004) (abuse-of-discretion standard—decision must follow guiding rules or principles)
In re RH White Oak, LLC, 442 S.W.3d 492 (Tex. App.—Houston [14th Dist.] 2014) (describes death-penalty sanctions as adjudicating the merits and precluding presentation of the case)