In Bunton v. Bentley, 176 S.W.3d 1 (Tex. App.--Tyler 1999), aff'd in part and rev'd & remanded in part, 94 S.W.3d 561 (Tex. 2002), Bunton, the host of a local public-access television show, and Gates, a participant on the program, appealed a judgment based on a jury verdict that each had defamed Bentley, a judge, and conspired to defame him. The judgment awarded Bentley $ 7,150,000 in actual damages plus $ 1,000,000 in exemplary damages for Bunton's defamation but only $ 95,000 in actual damages plus $ 50,000 in exemplary damages for Gates's defamation. Id. While finding that Bunton and Gates had conspired with one another to defame Bentley, the jury was not asked to find the amount of damages attributable to the conspiracy, nor did the trial court impose joint liability on the co-conspirators. Id. at 16. Bunton and Gates appealed. Bentley brought a cross-point urging that, in light of the jury's conspiracy finding, Gates should have been held jointly and severally liable with Bunton for the full amount of damages the jury awarded against Bunton. Id. at 15. Of relevance here, the Tyler Court of Appeals reversed the trial court's award of damages against Gates for defamation but overruled Bentley's cross-point regarding joint liability based on the conspiracy finding. The Court of appeals held that "in order to be entitled to judgment for joint and several liability, Bentley was required to secure a jury finding on the amount of damages he suffered as a result of the conspiracy itself." Id. at 17. It further observed that "the damages found by the jury against Bunton were not appropriate as against Gates because many of the defamatory acts occurred prior to Gates's involvement in the . . . program." Id.