Parkway Company v. Woodruff

In Parkway Company v. Woodruff, 901 S.W.2d 434, 444 (Tex. 1995), the Court stated that to survive a legal sufficiency challenge, the plaintiff must have presented "direct evidence of the nature, duration and severity of their mental anguish, thus establishing a substantial disruption in the plaintiff's daily routine." Id. at 444. If there is no direct evidence, the Court will apply "traditional 'no evidence' standards to determine whether the record reveals any evidence of a 'high degree of mental pain and distress' that is 'more than mere worry, anxiety, vexation, embarrassment, or anger' to support any award of damages." Id.