In Hawkins v. Walker, 238 S.W.3d 517 (Tex. App.--Beaumont 2007, no pet.), the jury awarded a total of $1,700,000 in damages to a mother for past and future mental anguish and for past and future loss of companionship and society arising from the death of her twenty-six-year-old daughter. Id. at 519-20. The total amount included awards of $500,000 for past loss of companionship and society, $500,000 for future loss of companionship and society, $500,000 for past mental anguish, and $200,000 for future mental anguish. Id. at 520. The trial court entered a judgment based on the jury's verdict. Id. The Beaumont Court of Appeals, in a two-to-one decision, held that the evidence was factually insufficient to support the jury's damage awards to the mother for mental anguish and loss of companionship and society. Id. at 532. Therefore, the court reversed the trial court's judgment in favor of the mother and remanded the mother's claims to the trial court for a new trial. Id. at 520. The court in Hawkins began its analysis by noting that the matter of whether factually sufficient evidence supports the damages awarded by the jury for nonpecuniary losses is a difficult question. Id. at 526-27. As stated by the court: "A court that reduces a jury's damage award faces criticism that it is not sympathetic to the loss suffered by the survivors. On the other hand, jury verdicts perceived as being excessive result in legislative efforts to cap the amounts that can be awarded in judgments, regardless of the damage suffered by the victim." Id. at 527. The court additionally noted that the remedy that allows a parent to recover nonpecuniary damages for the death of a child is a relatively recent one. Id. In Hawkins, during the last few years of the daughter's life, the mother and daughter saw each other several times a week and frequently talked with each other on the telephone. Id. at 525. They ate together several times a week. Id. The mother occasionally went shopping with her daughter, bought groceries for her daughter, paid her daughter's bills, and took her daughter to doctor's appointments. Id. The mother learned of her daughter's death during a telephone call. Id. at 525-26. She said that she could not believe she would never see her daughter again. Id. at 526. The mother testified that, when she learned of her daughter's death, she began screaming and could not stop. Id. The mother said that she loved her daughter very much, that she missed her daughter, and that she thought about her daughter every day. Id. The court in Hawkins explained that, while there was evidence that the mother and the decedent had a loving relationship, there was no testimony that the mother was dependent on the decedent or that the mother continued to suffer a severe grief reaction after her initial shock from learning of the decedent's death. Id. at 527. The court found it significant that there was no evidence that the mother suffered from depression as a result of her daughter's death, that the mother required any medical treatment to cope with her daughter's death, that the mother could no longer work as a result of her daughter's death, or that the daughter's death significantly interfered with the mother's daily activities. Id. The court noted the absence of evidence that the mother missed any work or changed her daily activities as a result of her daughter's death, that the mother was financially dependent on her daughter, or that the mother relied on the daughter for any advice or household services. Id. The Hawkins court then conducted a thorough examination of Texas and Fifth Circuit cases that involved factual sufficiency challenges to jury awards of nonpecuniary damages in wrongful death cases. Id. at 527-31. The court stated that "it had located only one case in which a Texas appellate court affirmed a jury award of more than $300,000 for a parent when the evidence did not include testimony consistent with the conclusion that the parent suffered severe mental anguish or severe grief because of the child's death." Id. at 527-28. The court noted that "there are reported Texas cases that affirm wrongful death awards for nonpecuniary damages of up to $300,000 when the evidence showed a close relationship but did not show any significant interference in the wrongful death beneficiary's daily activities." Id. at 528. The Hawkins court explained that the Fifth Circuit had affirmed large non-pecuniary damage awards when the testimony demonstrated "a severe depressive reaction lasting an unusually long time." Id. at 530. However, the court also noted that the Fifth Circuit had reversed such awards "when the evidence showed only a loving relationship between the decedent and the survivor." Id. at 529. The court stated that, "in our view, testimony that proves the beneficiary suffered severe mental anguish or severe grief should be a significant and sometimes determining factor in a factual sufficiency analysis of large non-pecuniary damage awards." Id. at 532. The court in Hawkins determined that Saenz requires appellate courts "to conduct a meaningful review of a jury's non-pecuniary damage awards in a wrongful death case, which, in turn, requires evidence 'that the amount found is fair and reasonable compensation.'" Id. at 531. The court additionally determined that "large non-pecuniary damage awards" required proof that the wrongful death beneficiary suffered severe mental anguish or severe grief. Id. at 532. The court concluded that the evidence, which consisted of the mother's testimony "that she had a close and loving relationship with her daughter and ate with her daughter regularly" was insufficient to support the jury's $1.7 million award of non-pecuniary damages because there was insufficient evidence to establish that the mother suffered severe emotional trauma that resulted in a lengthy depression or other severe secondary reaction or that the daughter's death resulted in a serious and permanent interference with the mother's daily activities. Id.