Breaches, but no Damages

Combs v. Crepeau involved a substantial judgment on a fiduciary-duty claim. The Fifth Court found legally insufficient damages evidence, holding as to past damages:

… there is no evidence of the value of the estate absent Michael’s fraud or breaches of fiduciary duty and no evidence from which a reasonable jury could find Diane and Lari’s combined one-half share of the estate was valued at $1,300,000.

That straightforward, high-level holding is supported by a painstaking review of many discrete components of that award. This case, and the damages arguments advanced in it, warrants study by anyone involved in document-intensive litigation about closely-held companies and family finances. No. 05-23-00088-CV (Oct. 7, 2024) (mem. op.).