Littleton v. Prange
Texas Court of Appeals
9 S.W.3d 223 (1999)
- Written by Galina Abdel Aziz , JD
Facts
Christie Lee Cavazos was a transgender woman who was born with male genitalia. Christie considered herself a female since she was three or four years old. At 23 years old, Christie enrolled in a program at the University of Texas that led to sex-reassignment surgery. Christie underwent psychological and psychiatric treatment for four years and legally changed her name to Christie Lee Cavazos. In 1980, Christie completed her sex-reassignment surgery. In 1989, Christie married Jonathon Mark Littleton, who was fully aware of Littleton’s history of sex reassignment. In 1996, Jonathon Littleton died, and Christie Littleton filed a medical-malpractice suit under the Texas Wrongful Death and Survival Statute (survival statute) against Dr. Prange, her husband’s doctor. During the pendency of the lawsuit, Christie amended her birth certificate pursuant to § 191.028 of the Texas Health and Safety Code (code), which allowed an individual to amend his or her birth certificate if it was incomplete or inaccurate. The court construed inaccurate to relate to the present and granted Christie’s amendment. The doctor filed a motion for summary judgment, alleging that Christie was not a proper wrongful-death beneficiary because Christie was a man. The trial court granted summary judgment. Christie appealed.
Rule of Law
Issue
Holding and Reasoning (Hardberger, C.J.)
Concurrence (Angelini, J.)
Dissent (López, J.)
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