In Thomas v. Oldham, 895 S.W.2d 352, 38 Tex. Sup. Ct. J. 375 (Tex. 1995), a broad-form damage question asked the jury to consider five separate elements in arriving at a single damage amount. The defendant did not object to the broad-form submission. In reaching its verdict, the jury made notations in the margin next to each of the five elements of damage. These notations totaled $ 500,000, which was the amount of the verdict. On appeal, the defendant challenged the verdict, arguing that there was no evidence to support the amounts noted by the jury on two of the five elements. The Court rejected the argument, observing that the jury's margin notations were not in legal effect "separate damage awards for purposes of evidentiary review." Thomas, 895 S.W.2d at 359. The Court further said that because the defendant had not asked for separate damage findings, it could only challenge the legal sufficiency of the evidence supporting the whole verdict. Id. at 360. Because the defendant did not make this argument, we rejected its evidentiary challenge. Id. The Court held that "a judgment in an action against a governmental unit under the Tort Claims Act bars the simultaneous rendition of judgment against the employee whose actions gave rise to the claim." Thomas, 895 S.W.2d at 357. Thomas presented us with two consolidated cases in which governmental employees and their employers had been sued over the employees' involvement in auto accidents. Both cases proceeded to trial; after trial, judgments were rendered simultaneously against both employees and their employers. Thomas, 895 S.W.2d at 354-55. The Court concluded that section 101.106 applies if a judgment is rendered against the governmental unit at any time during the pendency of the action against the employee. Thomas, 895 S.W.2d at 355. The Court further held that the actions against the employees did not terminate immediately upon rendition of judgment, but continued during the trial court's plenary power. Because the judgments against the governmental entities had been rendered while the actions against the employees were still pending, we concluded that those actions were barred. Thomas, 895 S.W.2d at 355-56. In Thomas the Court did not consider whether an interlocutory judgment would bar an action pursuant to section 101.106. Rather, the judgments in that case were both rendered after a trial on the merits.