Texas Personal Injury Causation: What Attorneys Must Prove

Causation Is an Essential Element: What Texas Personal Injury Attorneys Must Establish at Trial

Abstract

A defendant may have acted negligently. A collision may unquestionably have occurred. A patient may have significant pain, abnormal imaging, and thousands of dollars in medical treatment. Yet those facts do not automatically establish the complete causal chain required in a Texas personal injury case.

For personal injury attorneys, causation connects wrongful conduct to the event, the event to specific injuries, and those injuries to legally compensable damages. For healthcare professionals, the challenge is different but complementary: document how the mechanics of trauma, symptom timing, objective exam findings, diagnostic studies, pre-existing conditions, and functional losses support—or sometimes limit—a medical causation opinion.

Understanding these separate links can help attorneys develop stronger cases while helping clinicians remain within appropriate medical and evidentiary boundaries.

A Strong Injury Case Needs More Than Proof of Negligence

Imagine a client who is rear-ended while stopped at a traffic light in El Paso. Liability appears straightforward. The other driver admits looking at a phone immediately before impact.

Three days later, the client reports neck pain, headaches, numbness extending into the arm, difficulty sleeping, and trouble turning the head while driving. An MRI later reveals cervical disc abnormalities.

It may be tempting to tell the story as one uninterrupted conclusion: the defendant was negligent; therefore, the defendant caused every medical problem that followed.

Texas law requires a more disciplined analysis.

The Supreme Court of Texas has explained that establishing causation in a personal injury case requires proof that the defendant’s conduct caused an event and that the event caused the plaintiff to suffer compensable injuries. In JLG Trucking, LLC v. Garza, the Court emphasized that these are distinct causation inquiries, not assumptions that automatically follow from one another (JLG Trucking, LLC v. Garza, 2015).

For attorneys preparing a case for trial, that means working through four related but separate questions:

• Negligent conduct: What did the defendant do or fail to do, and why did it violate the applicable standard of reasonable care?
• Causation of the accident: Did that conduct actually cause the collision, fall, workplace incident, or other traumatic event?
• Causation of the injury: Did the event cause, aggravate, or materially contribute to the specific medical conditions being claimed?
• Compensable damages: What physical, functional, economic, and medical consequences resulted from those causally related injuries?

Overwhelming evidence about one link cannot necessarily repair a weakness in another.

Proving the Defendant Caused the Event

The first causation inquiry is largely legal and factual.

Consider a motor vehicle collision. Evidence might include the crash report, photographs, video, witness testimony, vehicle damage, electronic data, roadway evidence, and admissions by the drivers.

The attorney uses those facts to demonstrate how the defendant’s conduct caused the occurrence.

Texas proximate-cause principles generally incorporate cause in fact and foreseeability. “Cause” in fact asks whether the conduct was a substantial factor in bringing about the harm and whether the harm would have occurred without it. Foreseeability examines whether the general character of the danger should reasonably have been anticipated.

Importantly, a defendant’s conduct does not necessarily have to be the only cause. Texas Supreme Court authority recognizes that an injury may have more than one proximate cause, provided the conduct at issue satisfies the substantial-factor requirement (Windrum v. Kareh, 2019).

This becomes especially important in multi-vehicle collisions, premises cases with several contributing conditions, and cases involving subsequent accidents.

Proving the Accident Caused the Injury

The second causal bridge largely rests on medical evidence.

A jury can understand without extensive scientific explanation that a serious impact may cause certain immediately apparent injuries. But many personal injury disputes involve cervical disc conditions, radiculopathy, chronic headaches, ligament injury, aggravation of degeneration, neurological symptoms, or prolonged pain. These conditions may require qualified medical testimony connecting the event to the diagnosis.

Texas courts have recognized that expert testimony is generally required when medical causation falls outside ordinary juror knowledge. JLG Trucking relied on Guevara v. Ferrer for this principle and emphasized the plaintiff’s continuing burden to establish that the accident caused the claimed conditions.

This is where strong clinical documentation matters.

A medically defensible causation analysis does not simply say, “Patient was fine before the crash and hurt afterward.”

Instead, the record should explain the biological story.

In a rear-end collision, for example, rapid acceleration and deceleration can place unusual loads on cervical joints, muscles, ligaments, discs, and surrounding neurological structures. That mechanism may be consistent with a cervical acceleration-deceleration injury, but it alone does not prove that every later symptom originated in the collision.

The clinician must connect mechanics with anatomy and objective findings.

Chiropractic Care After Accidents and Injuries | El Paso, TX

Building the Medical Causation Chain

A strong medical record begins with a careful description of the event. Impact direction, occupant position, restraint use, secondary impact, head or trunk rotation, falls, and blunt contact can all affect the proposed mechanism.

The next question is temporal: when did symptoms begin, and how did they progress?

Then comes the examination. Clinically relevant findings may include measurable range-of-motion restrictions, muscle weakness, altered sensation, reflex abnormalities, orthopedic test findings, tenderness patterns, gait changes, neurological deficits, or reproducible functional limitations.

Imaging and other diagnostic studies can add evidence when medically indicated. However, never treat an MRI finding as a timestamp.

Degenerative disc findings are common even among people without pain. A systematic review of 3,110 asymptomatic individuals found that disc degeneration, bulges, protrusions, and other degenerative imaging findings become increasingly common with age. The authors emphasized that clinicians must interpret these findings in the context of the patient’s clinical presentation (Brinjikji et al., 2015).

For attorneys, that creates an important distinction: an abnormal MRI can identify anatomy, but the complete medical record must help explain whether the traumatic event caused a new injury, aggravated an existing condition, or merely coincided with an unrelated finding.

Pre-Existing Conditions Do Not End the Causation Analysis

Defense scrutiny often focuses on prior neck pain, back pain, degenerative changes, previous collisions, diabetes, neuropathy, arthritis, or earlier treatment.

Those facts should not be ignored.

They should be investigated.

A useful causation analysis reconstructs the patient’s pre-accident baseline. Was the patient symptomatic? Receiving treatment? Missing work? Experiencing neurological deficits? Limited in lifting, sleeping, driving, exercising, or performing household tasks?

Then you can compare the post-accident condition with that baseline.

This becomes especially important when another accident or medical condition represents a plausible alternative explanation. In JLG Trucking, the Texas Supreme Court concluded that evidence of a second automobile collision was relevant because it could bear directly on whether the first collision caused the claimed damages.

Strong medical causation opinions therefore address meaningful competing causes instead of pretending they do not exist.

Causation and Medical Expenses Are Not the Same Question

Texas attorneys should also distinguish causation from proof that treatment was necessary or charges were reasonable.

Texas Civil Practice and Remedies Code §18.001 provides a procedure involving affidavits concerning the reasonableness and necessity of services. But the statute expressly states that such an affidavit does not establish the causation element of the underlying claim.

That distinction is critical.

A treatment may have been medically necessary once a condition existed. The charge for that treatment may have been reasonable. Neither fact, standing alone, proves that the defendant’s accident caused the condition requiring treatment.

Causation must still be established.

For trial preparation, the medical narrative is stronger when the provider can explain why they selected a particular treatment, what condition it addressed, what objective findings supported that condition, how the patient responded, and why the provider believes the traumatic event caused or aggravated that condition.

Why Multidisciplinary Documentation Can Matter

Personal injury cases rarely involve only one dimension of health.

A patient may simultaneously have mechanical spinal dysfunction, soft-tissue injury, radicular symptoms, metabolic disease, medication considerations, sleep disruption, and reduced functional capacity.

At Injury Medical Clinic PA, Dr. Alex Jimenez, DC, APRN, FNP-BC, CFMP, IFMCP, combines the perspective of a Doctor of Chiropractic with that of a board-certified Family Nurse Practitioner. His clinical focus includes assessing musculoskeletal, spinal, neurological, joint, and soft-tissue injuries. The clinic also includes Dr. Maria Guadalupe Cardenas, MD, a board-certified internal medicine physician with more than 40 years of experience, who serves as Medical Director and Collaborative Physician. Clinic materials identify Dr. Jimenez’s Texas APRN license as #1191402 and NPI as 1205907805, while Dr. Cardenas is identified under Texas Medical License #J2933 and NPI 1164426748.

This structure provides a distinctive model for injury care in El Paso. Chiropractic physical medicine can address biomechanics, mobility, spinal function, and appropriate conservative rehabilitation, while advanced-practice nursing and physician-directed internal medicine can broaden diagnostic evaluation, risk assessment, laboratory testing when clinically justified, medication considerations, systemic disease evaluation, and treatment coordination.

For patients with soft-tissue and musculoskeletal injuries, coordinated care may include chiropractic rehabilitation, acupuncture or electroacupuncture, functional rehabilitation, diagnostic evaluation, and other medically appropriate treatment pathways. The clinical goal remains patient recovery—not creating a predetermined litigation narrative.

The practice publicly presents this combination of physician medical direction and dual-licensed DC/APRN injury care as a distinctive El Paso model. Use an absolute claim that it is the only clinic in El Paso offering every component of this treatment model only when the practice has documentation substantiating that exclusivity.

Objective Documentation Helps the Medical Story Survive Scrutiny

Insurance defense attorneys do not have to accept a causation opinion merely because it appears in a chart.

Texas Rule of Evidence 702 permits qualified expert testimony when specialized knowledge will assist the factfinder, while Rule 705 allows examination of the facts and data underlying an expert’s opinion. An opinion without an adequate factual foundation remains vulnerable.

That is why the strongest injury documentation connects the original event with mechanism, symptom chronology, prior health, examination findings, diagnostic evidence, functional losses, treatment decisions, reassessment findings, and competing explanations.

The objective is not to create more paperwork.

It is to create a record another qualified professional can follow.

Causation Is the Bridge From Liability to Damages

At trial, proving that a defendant acted negligently is not the end of the case.

The attorney must still connect that negligence to the occurrence, connect the occurrence to medically supportable injuries, and connect those injuries to the damages being requested.

The treating clinician’s responsibility is different but essential: accurately document what happened to the patient, identify what can be measured, evaluate alternative explanations, explain medically plausible relationships, and acknowledge reasonable limitations.

When attorneys and healthcare professionals respect those separate roles, causation becomes far more than the statement that symptoms started after an accident.

It becomes a structured evidentiary chain.

For Texas personal injury attorneys, that chain can help transform a collection of medical records into a coherent explanation of why the defendant’s conduct matters, what the trauma did to the patient, and which resulting losses can legitimately be presented to the jury.

For the injured patient, the same disciplined process serves an even more important goal: obtaining appropriate treatment, understanding what happened to the body, and making informed decisions about recovery.

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References

The following references support the article “Causation Is an Essential Element: What Texas Personal Injury Attorneys Must Establish at Trial.” They are formatted for inclusion at the end of your WordPress article, with hyperlinks to the original sources.

Brinjikji, W., Luetmer, P. H., Comstock, B., Bresnahan, B. W., Chen, L. E., Deyo, R. A., Halabi, S., Turner, J. A., Avins, A. L., James, K., Wald, J. T., Kallmes, D. F., & Jarvik, J. G. (2015). Systematic literature review of imaging features of spinal degeneration in asymptomatic populations. American Journal of Neuroradiology, 36(4), 811–816.

Guevara v. Ferrer, 247 S.W.3d 662 (Tex. 2007). https://law.justia.com/cases/texas/supreme-court/2007/2001030.html

Injury Medical Clinic PA. (n.d.). Meet the staff: Injury Medical Clinic PA. Dr. Alex Jimenez.

JLG Trucking, LLC v. Garza, 466 S.W.3d 157 (Tex. 2015). https://law.justia.com/cases/texas/supreme-court/2015/13-0978.html

Supreme Court of Texas. (2025). Texas rules of evidence (effective September 1, 2025).

Texas Legislature. (n.d.). Texas Civil Practice and Remedies Code § 18.001: Affidavit concerning cost and necessity of services.

Windrum v. Kareh, 581 S.W.3d 761 (Tex. 2019). https://law.justia.com/cases/texas/supreme-court/2019/17-0328.html