Casteel v. Crown Life Ins. Co
In Casteel v. Crown Life Ins. Co., 3 S.W.3d 582 (Tex. App.--Austin 1997), the Court held that the evidence supported a finding that Casteel "suffered from past mental anguish." 3 S.W.3d at 593.
The Court concluded, however, that "nothing in the record shows that the award of $ 6,000,000 is fair and reasonable compensation for that anguish." Id. (citing Saenz, 925 S.W.2d at 614).
Casteel does not hold that to recover mental-anguish damages, a plaintiff must present direct evidence of the value of mental anguish.
The Court held that there must be evidence to justify the amount awarded and that the amount must be fair and reasonable. See id.