Columbia Valley Healthcare System, L.P. v. Zamarripa (Opinion)Annotate this Case
An expert report required by the Texas Medical Liability Act must address proximate cause.
Plaintiff brought this health care liability claim against Hospital and others for the death of Yolanda Iris Flores. To satisfy the Act’s expert-report requirement, Plaintiff served two reports. Hospital argued that the expert reports did not adequately show causation. The trial court overruled the objection and denied Hospital’s motion to dismiss. The court of appeals affirmed, concluding that an expert report is not required to address proximate cause. The Supreme Court reversed, holding that Plaintiff’s expert reports did not show how Hospital caused Flores’s death, and therefore, the court of appeals’ judgment must be reversed and the cause remanded to the trial court for further proceedings.