Proximate cause is a required element of Texas negligence claims. This concept describes the link that must be proven between a defendant’s conduct (or lack thereof) and plaintiff’s injury. For example, a store might fail to use reasonable care by allowing a spill to remain on its floor. Subsequently, a customer might fall and hurt themselves. But if the person did not slip on the spill itself, no proximate cause exists.

The Supreme Court of Texas recently issued a decision in a case that tested the limits of proximate cause. Werner Enterprises v. Blake arose out of a horrific accident that occurred on Interstate 20 near Odessa when the road was extremely dangerous due to ice. A pickup truck driven by Todd Salinas was traveling between 50 and 60 miles per hour, when it slid across a 42-foot median into oncoming traffic and the path of an 18-wheeler. Shiraz Ali was a trainee driver for Werner Enterprises. He slammed on the brakes but could not avoid a collision that killed one child traveling with Salinas, and seriously inured three others.  

At trial, the jury awarded substantial verdicts to the plaintiffs, holding that Ali, though under the speed limit, was driving too fast given the conditions. The jurors’ decision indicated that they believed both parts of the proximate cause test were satisfied. First, the collision would not have occurred “but for” Ali’s carelessness. Second, Ali’s actions were a “substantial factor” in the accident.  

Upon review, the Texas Supreme Court disagreed and reversed the verdicts. Even assuming that the collision would not have occurred if Ali’s truck were traveling 15 miles per hour as opposed to 60, the justices ruled that the substantial factor test was not satisfied. According to the Court’s opinion, the cause of the accident was Salinas losing control of his vehicle and skidding more than 40 feet into the path of Ali’s truck. The opinion states that it was unfortunate happenstance that Ali’s truck was in a position to strike the pickup. 

For plaintiffs and defendants in personal injury cases, this ruling underscores the complexity of proving proximate cause. It’s not enough to demonstrate that the defendant’s negligence played a role in the incident; it must be proven that such negligence substantially caused the harm in question. This nuanced interpretation can significantly impact liability determinations and the outcome of negligence lawsuits.

Hope & Causey, P.C. pursues compensation for Texans in personal injury and wrongful death claims arising from all types of motor vehicle accidents. From our office in Conroe, we assist individuals from Montgomery County, San Antonio, Houston and the surrounding areas. Please call 936-441-4673 or contact us online today for a free consultation.