In the case of Syed Mohammed Bilal v. Sadaf Khan, decided by the Court of Appeals of Texas, Dallas, on May 30, 2025, Syed Mohammed Bilal appealed a jury verdict in favor of Sadaf Khan. Khan sued Bilal for unlawful disclosure of intimate visual material after he sent private videos of her to her mother without consent. The jury awarded Khan $140,000 for past mental anguish, $10,000 for future mental anguish, and $300,000 in exemplary damages, which the trial court capped at $350,000 total, including pre- and post-judgment interest. Bilal challenged the sufficiency of the evidence supporting the mental anguish damages. The appellate court affirmed the trial court’s judgment, finding the evidence legally and factually sufficient to support the awards.
Background
Sadaf Khan alleged that Bilal, whom she had dated, unlawfully obtained pornographic images and videos from her password-protected phone and sent them to her mother, Hina, in an attempt to coerce Khan into marrying him. Khan, a Pakistani Muslim, testified that such actions were particularly shameful in her community, where premarital sex and dating are stigmatized. The videos, which depicted Khan engaging in sexual intercourse with another man, were filmed with the man’s consent and intended to remain private. Bilal’s actions caused significant emotional distress, leading Khan to sue for compensatory and punitive damages under Texas law for unlawful disclosure of intimate visual material.
Trial Evidence
At trial, Khan detailed the profound emotional impact of Bilal’s actions. She testified that after learning Bilal had sent the videos to her mother, she became “very weak,” suffered from insomnia, and experienced severe anxiety that led to physical symptoms like vomiting and fever. Khan, a single mother with an autistic son, struggled to care for her children, missing school days and losing focus on their needs. She described withdrawing socially, disconnecting from friends, and experiencing a strained relationship with her mother due to the shame associated with the videos. Khan also noted a change in her personality, becoming “darker and less happy,” and stopped exercising, a habit that previously included walks with her children. She testified to ongoing depression and fear about who else might have seen the videos.
Hina, Khan’s mother, testified that she was “confused and ashamed” upon receiving the videos and had not discussed them with her husband due to their cultural implications. Khan’s testimony highlighted the loss of two close friends, whom she described as her “circle,” and a diminished ability to communicate with her mother. These disruptions persisted for over two and a half years, from the spring of 2021 to the trial in 2025.
Jury Findings and Trial Court Judgment
The jury found Bilal liable for unlawful disclosure of intimate visual material and determined that his actions were malicious, warranting exemplary damages. They awarded Khan $140,000 for past mental anguish, $10,000 for future mental anguish, and $300,000 in exemplary damages. The trial court applied a statutory cap, resulting in a total award of $350,000, plus interest. Bilal filed motions for a new trial, remittitur, and judgment notwithstanding the verdict, all of which were overruled by operation of law.
Appellate Issues
Bilal raised two issues on appeal:
Legal Sufficiency of Future Mental Anguish Damages ($10,000): Bilal argued there was no evidence to support the jury’s finding that Khan would suffer compensable mental anguish in the future.
Factual Sufficiency of Past Mental Anguish Damages ($140,000): Bilal conceded that Khan’s testimony provided legally sufficient evidence of past mental anguish but argued that the $140,000 award was excessive, claiming her distress lasted only “a few days.”
Appellate Court Analysis
The court applied established standards for reviewing legal and factual sufficiency challenges. For legal sufficiency, Bilal needed to show no evidence supported the future mental anguish award, with the court viewing evidence in the light most favorable to the verdict. For factual sufficiency, the court weighed all evidence to determine if the past mental anguish award was so contrary to the overwhelming evidence as to be clearly wrong and unjust.
Legal Sufficiency of Future Mental Anguish Damages
To recover future mental anguish damages, Khan needed to demonstrate a reasonable probability that her compensable mental anguish would persist. The court noted that mental anguish requires evidence of a high degree of mental pain and distress, beyond mere disappointment or embarrassment, and must substantially disrupt daily routines or cause significant emotional harm.
Khan’s testimony established ongoing disruptions at the time of trial, including the loss of two close friendships and the cessation of her exercise routine. Bilal argued that the lost friendships were not directly tied to the video disclosure, as Khan was unsure if her friends had seen the videos. However, the court found that Khan’s testimony linked her social withdrawal to the distress caused by Bilal’s actions, as she stated she “disconnected with [her] friends” due to depression. Regarding her exercise routine, Bilal contended Khan provided no evidence she would not resume exercising or context about the habit’s significance. The court disagreed, finding that Khan’s testimony about her ongoing inability to exercise supported a reasonable inference that this disruption would continue. Citing a precedent involving a revenge porn case, the court concluded that the jury could infer future mental anguish from Khan’s present distress, making the $10,000 award legally sufficient.
Factual Sufficiency of Past Mental Anguish Damages
For past mental anguish, the court required evidence of the nature, duration, and severity of Khan’s distress, showing either a substantial disruption in her daily routine or a high degree of mental pain. Khan’s testimony detailed depression, insomnia, loss of appetite, vomiting, fever, and an inability to focus on her children’s needs, including missing school days. She also described social isolation, a strained relationship with her mother, and a personality change. These effects spanned over two and a half years, far longer than the “few days” Bilal claimed, which referred to specific instances of fever and school absences.
The court compared Khan’s evidence to prior cases, such as a defamation case where a $150,000 award was upheld for similar disruptions (e.g., loss of sleep, stress, and social withdrawal) and a grave desecration case where anxiety and physical symptoms supported mental anguish damages. Khan’s award of $140,000 was significantly less than the $1.75 million she requested, and the court found it reasonable given the evidence of prolonged distress. The award was not so contrary to the evidence as to be clearly wrong or unjust, making it factually sufficient.
Conclusion
The appellate court overruled Bilal’s challenges, finding legally sufficient evidence for the $10,000 future mental anguish award based on ongoing disruptions and factually sufficient evidence for the $140,000 past mental anguish award based on the nature, duration, and severity of Khan’s distress. The trial court’s judgment was affirmed.
