De Escabedo v. Haygood

In De Escabedo v. Haygood, 283 S.W.3d 3 (Tex.App.--Tyler 2009), the Tyler Court was asked to review a similar evidentiary dispute relating to evidence of unadjusted medical bills. See id. at 5-6. De Escabedo argued that the unadjusted medical bills were irrelevant to and, therefore, no evidence of damages. Id. Ultimately, the Tyler Court agreed, concluding that, per Tex. Civ. Prac. & Rem. Code section 41.0105, evidence of unadjusted medical bills was inadmissible evidence and, therefore, there was no evidence to support the jury's award of past medical expenses. See id. at 7. The Tyler Court sustained De Escabedo's legal sufficiency challenge, and Haygood sought review from the Texas Supreme Court.