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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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