suitable expert claim (Texas) · Go Syfert
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suitable expert claim in Texas

18 Texas opinions name it 3 courts 2012–2026 9 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Columbia Valley Healthcare System, L.P. D/B/A Valley Regional Medical Center v. Maria Zamarripa, as Guardian of the Estates of R.F.R. and R.J.R., Minorsgreen
tex · 2017 · cited in 15 Texas opinions naming this issue, 2018–2026
2 sentences

2026The goal of section 74.351 is to “deter frivolous lawsuits by requiring a claimant early in litigation to produce the opinion of a suitable expert that his claim has merit.” Columbia Valley Healthcare Sys., L.P. v. Zamarripa, 526 S.W.3d 453, 460 (Tex. 2017) (internal quotation marks omitted); see also Certified EMS, Inc. v. Potts, 392 S.W.3d 625, 631 (Tex. 2013) (expert report requirement is “a threshold mechanism to dispose of claims lacking merit . . .”). 1 Pumphrey served Dr. Nambiar with a Supplemental Expert Report on December 19, 2025.

2025Laws 847 , 884. 3 Id. 4 Id. 4 opinion of a suitable expert that his claim has merit.’” 5 The fundamental goal is “to make health care in Texas more available and less expensive by reducing the cost of health care liability claims.” 6 Chapter 74 thus requires “a written report by an expert that provides a fair summary of the expert’s opinions . . . regarding applicable standards of care, the manner in which the care rendered . . . failed to meet the standards, and the causal relationship between that failure and the injury, harm, or damages claimed.” 7 While the report “need not marshal all the

1515
Tyler Scoresby, M.D. v. Catarino Santillan, Individually and as Next Friend of Samuel Santillan, a Minorgreen
tex · 2011 · cited in 14 Texas opinions naming this issue, 2012–2025
2 sentences

2025Laws 847 , 884. 3 Id. 4 Id. 4 opinion of a suitable expert that his claim has merit.’” 5 The fundamental goal is “to make health care in Texas more available and less expensive by reducing the cost of health care liability claims.” 6 Chapter 74 thus requires “a written report by an expert that provides a fair summary of the expert’s opinions . . . regarding applicable standards of care, the manner in which the care rendered . . . failed to meet the standards, and the causal relationship between that failure and the injury, harm, or damages claimed.” 7 While the report “need not marshal all the

2025Laws 847 , 884. 3 Id. 4 Id. 4 opinion of a suitable expert that his claim has merit.’” 5 The fundamental goal is “to make health care in Texas more available and less expensive by reducing the cost of health care liability claims.” 6 Chapter 74 thus requires “a written report by an expert that provides a fair summary of the expert’s opinions . . . regarding applicable standards of care, the manner in which the care rendered . . . failed to meet the standards, and the causal relationship between that failure and the injury, harm, or damages claimed.” 7 While the report “need not marshal all the

1414
Sue Abshire v. Christus Health Southeast Texas D/B/A Christus Hospital-St. Elizabethgreen
tex · 2018 · cited in 4 Texas opinions naming this issue, 2022–2024
2 sentences

2024Tex., 563 S.W.3d 219, 223 (Tex. 2018) (per curiam).

2023Tex., 563 S.W.3d 219, 223 (Tex. 2018) (per curiam).

44
Loaisiga v. Cerdagreen
tex · 2012 · cited in 3 Texas opinions naming this issue, 2018–2024
2 sentences

2024See Zamarripa, 526 S.W.3d at 460 (stating Section 74.351 intended to deter frivolous health care liability claims “by requiring a claimant early in litigation to produce the opinion of a suitable expert that his claim has merit”) (quoting Scoresby, 346 S.W.3d at 552 ); see also Loaisiga, 379 S.W.3d at 264 (stating expert report requirement creates “a low threshold a person claiming against a health care provider must cross merely to show that his claim is not frivolous”).

2019Therefore, “[a]n expert report . . . is a low threshold a person [bringing a claim] against a health care provider must cross merely to show that his claim is not frivolous.” Loaisiga v. Cerda, 379 S.W.3d 248, 264 (Tex. 2012).

33
Certified Ems, Inc. D/B/A Cpns Staffing v. Cherie Pottsgreen
tex · 2013 · cited in 1 Texas opinions naming this issue, 2026–2026
1 sentence

2026The goal of section 74.351 is to “deter frivolous lawsuits by requiring a claimant early in litigation to produce the opinion of a suitable expert that his claim has merit.” Columbia Valley Healthcare Sys., L.P. v. Zamarripa, 526 S.W.3d 453, 460 (Tex. 2017) (internal quotation marks omitted); see also Certified EMS, Inc. v. Potts, 392 S.W.3d 625, 631 (Tex. 2013) (expert report requirement is “a threshold mechanism to dispose of claims lacking merit . . .”). 1 Pumphrey served Dr. Nambiar with a Supplemental Expert Report on December 19, 2025.

11
American Transitional Care Centers of Texas, Inc. v. Palaciosgreen
tex · 2001 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025Transitional Care Ctrs. of Tex., Inc. v. Palacios, 46 S.W.3d 873, 877 (Tex. 2001))). 7 Tex. Civ.

11
New Medical Horizons, II, Ltd. D/B/A Cypress Fairbanks Medical Center v. Vickie Milnergreen
texapp · 2019 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025Horizons, II, Ltd. v. Milner, 575 S.W.3d 53, 59 (Tex. App.—Houston [1st Dist.] 2019, no pet.) (citing TEX.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Larson v. Downing green
tex · 2006
1 sentence

2024Although the Amended Report could have provided a more robust discussion of Dr. Lapuerta’s opinion on the causal relationship 33 between Dr. Horndeski’s breach and Price’s harm, we nevertheless consider it sufficient, and to the extent the report’s adequacy is a close call with respect to causation, “[c]lose calls must go to the trial court.” Larson, 197 S.W.3d at 304 .

12024–2024
Scoresby v. Santillan green
texapp · 2009
1 sentence

2015We 15. 287 S.W.3d at 324 . 19. 1977 Act, § 1.02(a)(5H6). 16.

12015–2015

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