Davis v. Davison

I concur with the majority. Although this case does not involve unique issues of law, it *792does present the recurring problem arising from a jury verdict of liability coupled with an award of $0 damages.

The “zero damages rule” is one method which Texas courts have employed to review a jury’s finding of no damages. Hammond v. Estate of Rimmer, 643 S.W.2d 222, 223 (Tex.App.—Eastland 1982, writ ref'd n.r.e.). When applied in the strictest sense, it simply means that in eases involving unliquidated damages, the jury must award something for every element of damage proved, or else the case will be…