In re Columbia Medical Center of Las Colinas, Subsidiary, L.P – Case Brief Summary (Texas)

In In re Columbia Medical Center of Las Colinas, Subsidiary, L.P., 290 S.W.3d 204 (Tex. 2009), the Texas Supreme Court held that "parties to a dispute who choose to have the dispute resolved by a jury and endure the personal and financial inconvenience of such a trial are entitled to know why the verdict was disregarded." Id. at 211.

"Jury trials are essential to our constitutionally provided method for resolving disputes" yet trial courts that overturn a jury verdict enjoy both wide discretion to do so and a limited appellate standard of review. See id.

Accordingly, trial courts must specify the basis for overturning a jury's decision. Id.

The Texas Supreme Court also held that a trial court abused its discretion by failing to specify the reasons for its decision granting a new trial "in the interest of justice." See In re Columbia, 290 S.W.3d at 213.

The Court concluded, "the parties and the public are entitled to an understandable, reasonably specific explanation why their expectations that a jury verdict will close the trial process are frustrated by a jury verdict being disregarded, or set aside, the trial process being nullified, and the case having to be retried." In re Columbia, 290 S.W.3d at 213.

The Court conditionally granted mandamus relief, and directed the trial court judge to specify its reasons for granting a new trial. Id. at 215.

Because the trial court's order did not include the reasons for its ruling, the Court expressly declined to consider the realtor's request for a writ of mandamus directing the trial court to enter judgment on the verdict. Id. at 214.

Generally a writ of mandamus will issue only to correct a clear abuse of discretion or the violation of a duty imposed by law, in circumstances when a regular appeal is not an adequate remedy. In re Columbia, 290 S.W.3d at 207.