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156 S.W.3d 574 IN RE S.A.P.
135 S.W. 3d 165 IN RE S.A.P.
80 S.W. 3d 232 IN RE J.M.M
963 S.W. 2d 550 Avery vs. State

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6. We have found no court of appeals case extending Crown Life to error in submission of a liability theory supported by no evidence. Courts of appeals are split as to whether Crown Life extends to cases where an element of damages should not have been submitted because of lack of supporting evidence. Com­pare Wai-Man Stores, Inc. v. Redding, 56 S.W.3d 141, 154-55 (Tex.App.--Houston [14th Dist] 2001, no pet.) (reviewing court must presume error harmful in submitting element of damages supported by no evidence and jury question did not require separate findings), and Iron Mountain Bison Ranch, Inc. v. Easley Trailer Mfg., Inc., 42 S.W.3d 149, 157 (Tex.App.--Amarillo 2000, no pet.) (error harmful under Crown Life when no evidence supported submission of lost prof­its), with Harris County v. Smith, 66 S.W.3d 326, 333 (Tex.App.--Houston [1st Dist.] 2001, pet. granted) (holding Crown Life's presumed harm analysis does not apply when trial court erroneously submits elements of broad-form damages question).





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