Jose Ignacio Mendez-Martinez, M. D. v. Andres G. Carmona, Individually, on Behalf of All Wrongful Death Beneficiaries, and as Personal Representative of the Estate of Rosario M. Carmona, 510 S.W.3d 600

Rosario Carmona was admitted to Sierra Providence Hospital with atrial fibrillation and other conditions; she died of cardiac arrest six days later.
Between 8:00 PM on May 7 and early morning May 8, Carmona had persistent tachycardia, a Cardizem drip, later bradycardia (heart rate in the 40s), and gaps in monitoring; she was found pulseless at 7:14 AM.
Plaintiff Andres Carmona sued the treating cardiologist Dr. Jose Ignacio Mendez‑Martinez and the hospital for malpractice, alleging failure to transfer the patient to the ICU for closer monitoring and failure to be at bedside after clinical changes.
Plaintiff served an expert report from Dr. Louis Roddy; the trial court found the initial report deficient on causation, granted leave to supplement, and accepted a supplemental report as curing the deficiency.
Dr. Roddy’s supplement asserted ICU nurses’ specialized monitoring would have detected deterioration, reported it to the physician, and that earlier rhythm/rate control or cardioversion would more likely than not have prevented the cardiac arrest and death.
Only Dr. Mendez‑Martinez appealed the trial court’s denial of his motion to dismiss under the Texas Medical Liability Act (TMLA); the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether expert report improperly collectivizes multiple defendants	Roddy delineated separate duties: physician must transfer to ICU and attend bedside on acute change; nurses must monitor q30min and notify physician	Mendez‑Martinez argued report failed to apportion blame or specify his comparative causal contribution versus nursing negligence	Court: report sufficiently distinguished roles and linked breaches to harm; no requirement to assign percentages; issue overruled
Whether expert report sufficiently establishes causation between failure to transfer and death	Roddy explained ICU training/monitoring differences, that ICU q30min monitoring would likely have detected deterioration and led to physician-ordered interventions preventing arrest	Mendez‑Martinez argued report was conclusory: did not show ICU monitoring differed meaningfully from floor monitoring or that earlier detection would have altered an allegedly sudden collapse	Court: reading the report as a whole, it provided a fair summary and logical chain tying the breach to harm; causation adequately pleaded; issue overruled

TTHR Ltd. P’ship v. Moreno, 401 S.W.3d 41 (Tex. 2013) (defines expert-report requirements under the TMLA)
Tenet Hospitals, Ltd. v. De La Riva, 351 S.W.3d 398 (Tex.App.—El Paso 2011) (causal‑relationship standard: negligent act must be a substantial factor)
Clapp v. Perez, 394 S.W.3d 254 (Tex.App.—El Paso 2012) (expert report must link conclusions to facts and explain basis of opinions)
Bustillos v. Rowley, 225 S.W.3d 122 (Tex.App.—El Paso 2005) (failure to monitor can support liability where report shows missed, treatable deterioration)
Tenet Hosps., Ltd. v. Love, 347 S.W.3d 743 (Tex.App.—El Paso 2011) (expert must delineate standards applicable to each defendant)
Certified EMS, Inc. v. Potts, 392 S.W.3d 625 (Tex. 2013) (one adequate theory in an expert report is sufficient to uphold denial of dismissal)