PJC Business

D AMAGES

PJC 115.24

overruled on other grounds by Dallas Market Center Development Co. v. Liedeker , 958 S.W.2d 382 (Tex. 1997); Lone Star Steel Co. v. Wahl , 636 S.W.2d 217, 221 (Tex. App.—Texarkana 1982, no writ) (measure of damages is all wages past due and all future promised wages less what can be earned by reasonable effort in similar employ ment). There may be elements of actual damages that are recoverable other than those listed in PJC 115.24. Separate answer for each element. Broad-form submission of multiple elements of damages may lead to harmful error if there is a proper objection raising insuffi ciency of the evidence to support one or more of the elements submitted. Harris County v. Smith , 96 S.W.3d 230, 233–34 (Tex. 2002). If there is any question about the sufficiency of the evidence to support one or more of the elements, the Committee rec ommends that the elements of damages be separately submitted to the jury. Consequential damages. If foreseeability is at issue, see PJC 115.5 and make appropriate modifications.

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