Thota v. Young, 366 S.W.3d 678

Ronnie Young died in 2005 after complications from a 2002 cardiac catheterization performed by Thota, leading to a tear in the right iliac artery and extensive bleeding.
Ronnie suffered multiple complications from the bleed, including renal failure, transfusions, surgeries, and long-term disability before his death from leukemia linked to his polycythemia vera.
Margaret Young brought a medical-malpractice claim on her own behalf and as estate representative against Dr. Thota and NTCC, alleging negligent conduct in the catheterization and post-procedure care.
The trial featured a single broad-form negligence theory with separate blanks for Dr. Thota and Ronnie, plus questions on contributory negligence and a new-and-independent-cause defense; defense urged multiple theories and defenses but no granulated submission was requested.
The court of appeals held that the contributory-negligence and new-and-independent-cause instructions were harmful error under Casteel because they mixed valid and invalid theories, and remanded for a new trial.
The Texas Supreme Court granted review to address whether Casteel’s presumed-harm framework applies in a single-theory case with defensive inferential rebuttals and whether the charge errors were reversible under traditional harmless-error standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Casteel’s presumed-harm analysis applies to a single-theory case with an improper defensive instruction.	Young argued Casteel applies because the broad-form charge mixed valid and invalid theories.	Thota contends Casteel does not apply in a single-theory case with inferential rebuttals.	Casteel does not apply; use traditional harmless-error analysis.
Whether the Ronnie contributory-negligence question was harmful error.	Young contends the question was inappropriate and prejudicial.	Thota argues no prejudice given the jury found no liability for Thota.	Harmless error; verdict unaffected.
Whether the new-and-independent-cause instruction was harmful error.	Young contends it improperly shielded Thota from liability.	Thota contends any error was harmless given evidence and trial posture.	Harmless error under the record.
Whether the error preservation requirements were satisfied for Casteel review.	Young preserved objections timely and specifically at trial.	Thota argues preservation was lacking for Casteel-centered analysis.	Error preserved; traditional harmless-error review applied.

Crown Life Ins. Co. v. Casteel, 22 S.W.3d 378 (Tex. 2000) (presumed harm when broad-form merges valid and invalid theories)
Harris Cnty. v. Smith, 96 S.W.3d 230 (Tex.2002) (harm analysis for commingled damage elements)
Bed, Bath & Beyond, Inc. v. Urista, 211 S.W.3d 753 (Tex.2006) (limits of Casteel to multi-theory issues; favors traditional analysis in single-theory with inferential rebuttals)
Romero v. KPH Consolidation, Inc., 166 S.W.3d 212 (Tex.2005) (applies presumed-harm to proportionate-responsibility questions with unsupported claims)
Elbaor v. Smith, 845 S.W.2d 240 (Tex.1992) (preservation and error standards for jury-charge objections)
Urista v. Bed, Bath & Beyond, 211 S.W.3d 753 (Tex.2006) (rejects extending Casteel to inferential rebuttal instructions; uses traditional harmless analysis)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex.2005) (credibility and weight of witness testimony; standard in evaluating evidence)
Block v. Mora, 314 S.W.3d 440 (Tex.App.-Amarillo 2009) (discusses multi-party broad-form issues and Casteel considerations)