The Texas Supreme Court recently overturned a $116 million verdict against a trucking company and its driver, reasoning that, as a matter of law, the trucking company and its driver did not proximately cause the plaintiffs’ injuries.

In December 2014, the National Weather Service issued a winter weather advisory indicating that ice was likely to accumulate on the roads and cause hazardous driving conditions. Trey Salinas (“Salinas”) was driving his F-350 pickup along with four passengers—Jennifer Blake and her three children (the “Blakes”)—heading eastbound on I-20 near Odessa. Werner Enterprises’ (“Werner”) 18-wheeler driven by Shiraz Ali (“Ali”) was heading westbound on I-20. In approximately two seconds, Salinas’ F-350 lost control and left the I-20 eastbound lanes, crossed the 42-foot grassy median, and collided with Werner’s 18-wheeler in the westbound lanes.

The Blakes sued Werner and Ali. The jury found Werner and Ali liable, and the district court rendered judgment against Werner and Ali in the amount of $116 million. An en banc court of appeals affirmed the district court’s judgment, and Werner Enterprises and Ali appealed to the Texas Supreme Court.

The Supreme Court of Texas reversed and rendered judgment in favor of Werner and Ali reasoning that a negligent actor incurs liability only for damages proximately caused by his negligence and Werner’s and Ali’s negligence did not proximately cause the Blakes’ injuries.

Here, the Court explained that proximate cause requires, among other things, proof that the defendant’s negligence was a substantial factor in causing the injury. The substantial-factor requirement means that liability falls only on a party whose substantial role in bringing about the injury is such that he is “actually responsible for the ultimate harm.” Transcon. Ins. Co. v. Crump, 330 S.W.3d 211, 224 (Tex. 2010).

The Blakes contend that if Ali had not been driving too fast in the icy conditions, the Blakes vehicle would not have collided with anything and safely spun across the roadway and into the grass.  On this point the court of appeals agreed that a reasonable juror could consider Ali’s speed a proximate cause of the Blakes’ injuries.

However, the Court explained that this argument only addressed the but-for causation and did not account for the requirement of substantial-factor causation. The Court held that the sole substantial-factor was the sudden, unexpected hurtling of Salinas’ vehicle into oncoming traffic, and that no reasonable juror could assign responsibility to Werner or Ali for the Blakes’ injuries. Therefore, the Court concluded as a matter of law, the Blakes did not establish that Werner and Ali proximately caused their injuries and overturned the $116 million verdict.

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