January 2026. Congratulations to Patrick Madden and Sandra Horne for prevailing by summary judgment in Tarrant County! The plaintiffs in this case alleged that injuries to themselves and their animals were caused by exposure to an herbicide product. The plaintiffs’ evidence of causation was primarily based on timing; that is, the plaintiffs’ claimed that the onset of their symptoms coincided with their exposure to the herbicide. In Texas, plaintiffs cannot prove that personal injuries were caused by toxic chemicals based only on “temporal proximity” to the exposure. In other words, plaintiffs’ evidence must prove more than that their symptoms arose immediately after their exposure to the chemical. In this case, the plaintiffs did not have (a) adequate scientific evidence that the herbicide could cause the type of injuries alleged by plaintiffs; and (b) adequate medical evidence that exposure to the herbicide was the cause in fact of plaintiffs’ alleged injuries. The court sustained our objections to most of the plaintiffs’ summary judgment evidence and granted summary judgment, dismissing all plaintiffs’ claims with prejudice.