Monroe v. Grider

In Monroe v. Grider, 884 S.W.2d 811, 820 (Tex. App.--Dallas 1994, writ denied) the court of appeals properly drew a distinction between a jury's failure to award damages for pain and suffering when there was objective, undisputed evidence of injury and the jury's failure to award damages for mental anguish. In that case, the trial court had submitted physical pain and mental anguish in one issue. The jury failed to award any damages in that category, although the plaintiff had a fractured wrist and a sprained muscle in her groin that "temporarily prevented her from working and fully enjoying recreational activities." Id. at 819. The court of appeals held, "uncontroverted evidence of an objective injury does not always require mental anguish damages," but the jury could not ignore uncontroverted evidence of injury in denying any recovery for past physical pain. Id. at 820.