In Dennis v. Haden, 867 S.W.2d 48 (Tex. App.--Texarkana 1993, writ denied), the trial court ordered the defendants to provide expert reports for all experts they expected to call as witnesses. Id. at 50.
That was not done for one of the experts, and Dennis objected. The trial court overruled the objection and allowed the expert to testify.
On appeal, the reviewing court agreed that it was error because "the trial court's action appears to have occurred in disregard of its own directives." Id. at 51.
Consequently, it abused its discretion "in allowing the expert to testify after the defendant failed to obey the court order by not providing a report . . . ." Id.