In Lancaster v. Fitch, 112 Tex. 293, 246 S.W. 1015, 1016 (Tex. 1923), the trial court submitted a single general negligence issue with instructions regarding three distinct theories of negligence liability. Lancaster, 246 S.W. at 1015-16. The jury returned a verdict for the plaintiff. On appeal, the defendant established that the trial court should not have submitted one of the theories. The court of appeals nevertheless concluded that the error was harmless because the jury could have based its verdict on either of the properly submitted theories. The Court disagreed, reasoning: The jury may have found for [plaintiff] on each of the two issues properly submitted. On the other hand, as authorized by the pleading and the charge of the court, they may have found for [plaintiff] only on the issue that was improperly submitted. In order for courts to be able to administer the law in such cases with reasonable certainty and to lay down and maintain just and practical rules for determining the rights of parties, it is necessary that the issues made and submitted to juries, and upon which they are required to pass, be authorized and supported by the law governing the case. Lancaster, 246 S.W. at 1016.