Douglas v. Delp
In Douglas v. Delp, 987 S.W.2d 879 (Tex. 1999), the supreme court stated that mental-anguish damages were not allowed when the defendant's negligence harmed only the plaintiff's property. Id. at 885.
In those cases, damages measured by the economic loss would make the plaintiff whole. Id.
Applying those concepts to attorney malpractice, the court stated that limiting the plaintiff's recovery to economic damages would fully compensate the plaintiff for the attorney's negligence. Id.
The court concluded "that when a plaintiff's mental anguish is a consequence of economic losses caused by an attorney's negligence, the plaintiff may not recover damages for that mental anguish." Id.