In Univ. of Tex. S.W. Med. Ctr. at Dallas v. Estate of Arancibia, 324 S.W.3d 544 (Tex. 2010), there was only one possible instrumentality of the harm--the governmental actor. See 324 S.W.3d at 549-50. Additionally, in that case, the record showed that the governmental actor was subjectively aware, within days of the fatality, that its error alone caused the complained-of injury. See id. Irene Arancibia died three days after two resident physicians performed laparoscopic hernia surgery on her. Id. at 546. Arancibia was released from the hospital the same day of the surgery, but returned to the emergency room two days later with severe abdominal pain. Id. Emergency surgery showed that during the hernia operation, her bowel was perforated, leading to acute peritonitis, sepsis, and ultimately her death. Id. The Supreme Court of Texas held that the record showed Southwestern Medical Center was subjectively aware of its fault as ultimately alleged by the Arancibias, and that it had actual notice of the claim, under the Texas Tort Claims Act. Id. at 550. Dr. Watson, an attending physician, was present while the two resident physicians performed the hernia repair. Id. at 549. The day after Arancibia's death, Dr. Watson emailed his immediate supervisor, who was the chief of the gastrointestinal/endocrine division. Id. at 546, 549. Dr. Watson wrote that he wanted to give his supervisor a "heads up on a terrible outcome with" a patient. Id. at 549. He described the surgery, which he believed went well, and the patient's return to the emergency room with "an unrecognized bowel injury." Id. He stated that "I have already spoken with risk" management. Id. Shortly thereafter, having reviewed Arancibia's treatment, Dr. Watson's supervisor concluded that a "technical error occurred during the original hernia operation resulting in" two perforations in Arancibia's small intestine, and further that "clinical management contributed to" Arancibia's death. Id. The supervisor stated that "although unfortunate, this is a recognized complication of laporoscopic hernia surgery. No standard of care issues were identified upon review." Id. The Supreme Court concluded that Southwestern was subjectively aware of its fault as ultimately alleged by the Arancibias, and that Southwestern could not evade the actual-notice determination by subjectively refuting its fault. Id. at 550. The Supreme Court observed that the purpose of the notice requirement is to enable governmental units to investigate and address claims appropriately, which was satisfied by Southwestern's actual notice. Id.