In re Columbia Medical Center of Las Colinas

In this mandamus case, we must decide whether a trial court abused its discretion by refusing to reduce a punitive damages award where such damages were statutorily capped as measured against an economic damages award. We hold that it did. In a previous appeal of this same underlying case, we rendered a judgment that reduced the amount of economic damages awarded. Columbia Med. Ctr. of Las Colinas, Inc. v. Hogue, 271 S.W.3d 238, 257 (Tex. 2008). Although our judgment did not also expressly order a reduction of the award of punitive damages, it is what the statute requires. See TEX. CIV. PRAC. & REM. CODE § 41.008(b). Accordingly, we conditionally grant the writ of mandamus.

In the underlying suit, the widow and sons of Robert Hogue, Jr. won a jury verdict on their medical malpractice claims against Columbia Medical Center. The trial court and court of appeals awarded them economic and punitive damages. Id. (capping any punitive damages award at (1) two times any amount of economic damages plus (2) an amount equal to any non-economic damages not exceeding $750,000). On appeal, we reversed the judgment of the court of appeals in part, vacating a portion of the economic damages award-loss of inheritance damages-for want of legally sufficient evidence, while affirming the rest of the judgment. Columbia Med. Ctr., 271 S.W.3d at 257. Our judgment read in relevant part: