Service Corp. International v. Guerra, 348 S.W.3d 221

Background

SCI Texas owns Mont Meta Memorial Park and is wholly owned by SCI International through an intermediary; the Guerra family burial plot was sold to others; Mont Meta moved Mr. Guerra's body without the family's permission after discovering the plot issue; multiple Mont Meta employees and records indicated connections to SCI; the Guerras sued SCI Texas and SCI International for fraud, intentional infliction of emotional distress, negligence, and trespass; a jury found liability and awarded damages including exemplary damages; the court of appeals affirmed with modification but SCI challenged liability and damages against SCI International and admission of other lawsuits evidence.
The trial record showed a blind check of plot locations, misstatements about plot quitclaims, and subsequent disclosure that Mr. Guerra’s body had been moved laterally; the family declined the cemetery’s request to move the body but the move occurred; the Guerras alleged a pattern of misconduct across SCI entities and sought punitive damages and injunctive relief.
The Supreme Court of Texas held that there was legally insufficient evidence to support liability findings against SCI International or the daughters’ mental anguish damages; the trial court erred in admitting evidence of other lawsuits against SCI Texas; the case was reversed and remanded for a new trial, with specific remand directions on damages against SCI Texas and Mrs. Guerra.
On remand, the court rendered Julie, Gracie, and Mary Ester Martinez and SCI Texas take nothing from SCI International, and Mrs. Guerra takes nothing from SCI International; Mrs. Guerra’s claim against SCI Texas is remanded for a new trial.
Notes and procedural posture discussed include preservation and relevance of other-suits evidence, and that the punitive-damages-trust testimony was not admissible for retrial guidance.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Liability of SCI International for Mont Meta employees	Guerras argued SCI Intl. employed Mont Meta workers.	SCI Intl. contended workers were not SCI Intl. employees; status was not established.	No legally sufficient evidence of SCI Intl. employment; liability reversed for SCI Intl.
Mental anguish damages for daughters	Daughters suffered compensable mental anguish from body move.	Evidence inadequate to prove high degree of distress or disruption for daughters.	Daughters' mental anguish damages not supported.
Admission of other-suits evidence	Evidence showed a pattern of misconduct by SCI.	Evidence lacked sufficient connection to the Guerras' facts; improper.	Admission of other-suits evidence was harmful and reversed for new trial.
Damages and remand scope	Damages should be sustained; but issue viability remains.	Some liability theories invalid or indistinguishable; remand needed.	Remand for new trial; SCI Texas claim remanded; others take nothing against SCI Intl.

Key Cases Cited

King Ranch, Inc. v. Chapman, 118 S.W.3d 742 (Tex.2003) (no-evidence standard for sufficiency and inference limitations)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex.2005) (judicial use of inferences; speculative evidence not enough)
Parkway Co. v. Woodruff, 901 S.W.2d 434 (Tex.1995) (requirements for proving mental anguish and need for direct evidence)
Bentley v. Bunton, 94 S.W.3d 561 (Tex.2002) (direct evidence required for massive damages; disruption and distress standard)
Likes v. Gunn Infiniti, 962 S.W.2d 495 (Tex.1997) (mental anguish damages require specific evidence of impact on daily life)
Gunn Infiniti v. O'Byrne, 996 S.W.2d 854 (Tex.1999) (mental anguish standards; detail sufficiency of evidence)
In re J.F.C., 96 S.W.3d 256 (Tex.2002) (deemed findings require evidentiary support when elements omitted from charge)