Transcon. Ins. Co. v. Crump

In Transcon. Ins. Co. v. Crump, 330 S.W.3d 211 (Tex. 2010), the evidence reflected that Crump struck his knee while at work, that the injury caused a contusion and hematoma, that increasingly serious complications arose, and that Crump died about eight months after his initial injury. 330 S.W.3d at 214. The knee injury was determined to be a compensable injury, but the dispute centered on whether the knee injury was a producing cause of Crump's death eight months later. Id. Producing cause was the only issue that the trial court submitted to the jury in that case. Id. at 215. Holding that the incorrect definition of producing cause was harmful, the supreme court stated: "The but-for aspect of causation was squarely at issue in this case, and the sole question before the jury was whether the May 2000 injury was a producing cause of Crump's death." Id. at 226.