Larry Whitfield, M.D. & Texomacare v. Marjoyrie Henson, Individually and as Next Friend of Ramont Davis, 385 S.W.3d 708

Henson sued multiple health care providers for negligent care in summer 2009 that allegedly caused prematurity and numerous injuries to her son RD.
RD was born at ~27 weeks with severe, lasting medical problems; RD required resuscitation, then developed multiple complications.
Henson alleged providers failed to test for pregnancy, diagnose pregnancy, refer to OB/GYN, and prescribed medications contraindicated in pregnancy.
Henson served six expert reports under Texas Civil Practice and Remedies Code §74.351; defendants moved to dismiss for lack of causation.
The trial court denied the motions to dismiss; the matter proceeded to interlocutory appeal on the issue of causation in the expert reports.
The Texas appellate court affirmed, holding Atlas’s report satisfied §74.351’s causation requirements and the trial court did not abuse its discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Atlas’s report satisfy §74.351 causation requirements?	Atlas’s opinion ties lack of prenatal care and improper meds to RD’s injuries.	Report is conclusory and fails to link injuries to specific causation theories.	Yes; Atlas's report satisfies the statute and supports merit of claims.
Did the trial court abuse its discretion in denying dismissal?	Denial was proper because causation report met statutory requirements.	Denial was improper due to conclusory causation opinions.	No; trial court’s denial affirmed.

Palacios v. American Transitional Care Centers of Texas, Inc., 46 S.W.3d 873 (Tex. 2001) (threshold expert-report function to deter frivolous claims while preserving potentially meritorious ones)
Samlowski v. Wooten, 332 S.W.3d 404 (Tex. 2011) (expert report must be a good-faith effort showing merit and implicating defendant's conduct)
Scoresby v. Santillan, 346 S.W.3d 546 (Tex. 2011) (reaffirms purpose of expert-report requirement and minimal sufficiency)