In a significant decision issued on June 27, 2025, the Supreme Court of Texas reversed a jury verdict awarding over $89 million in damages in favor of the plaintiffs in Werner Enterprises, Inc. v. Blake, holding that the plaintiffs failed to establish proximate cause as a matter of law. The ruling explains the burden plaintiffs face in proving that a defendant’s negligence was not only a but-for cause of injury but also a substantial factor in bringing it about. The Court clarified that an employer cannot be held liable — under either derivative or direct theories — if the employee’s conduct is not a proximate cause of the injury.
FACTUAL BACKGROUND
The case arose from a tragic 2014 highway collision near Odessa, Texas. Trey Salinas, driving a Ford F-350 with four passengers, lost control on an icy interstate, crossed a 42-foot-wide median, and collided with a Werner Enterprises 18-wheeler driven by Shiraz Ali. The crash killed one child and severely injured the others. Plaintiffs alleged that Ali was driving too fast for the icy conditions, even though he was below the posted speed limit. Plaintiffs further alleged Werner was negligent in training and supervising Ali and in sending Ali, an inexperienced trainee driver, into winter weather without access to important weather updates.
At trial, the jury found Werner and Ali liable. The court of appeals affirmed and concluded that Ali’s speed was a proximate cause of the injuries.
THE SUPREME COURT’S HOLDING
The Texas Supreme Court reversed, holding that the plaintiffs failed to prove that Ali’s conduct was a substantial factor in causing the injuries. While acknowledging that Ali’s speed may have been a but-for cause, the Court emphasized that proximate cause requires more: the defendant’s conduct must be a substantial factor that makes the defendant “actually responsible for the ultimate harm.”
The Court concluded that the sole proximate cause of the accident was Salinas’s loss of control and sudden incursion into oncoming traffic. Ali’s presence on the highway and his speed, though arguably negligent, merely created the condition that made the injury possible. They were not substantial factors in causing the harm.
The Court reaffirmed that proximate cause consists of two elements: cause-in-fact and foreseeability. The Court focused on the substantial factor component of cause-in-fact and stressed that, even if the defendant’s negligence is part of the causal chain of events that led to the injury, liability cannot be imposed based on a mere “happenstance of place and time.” The Court held that liability does not fall on other participants in the causal chain whose actions merely “created the condition which made the injury possible.”
IMPACT ON FUTURE CASES
This decision sets a higher standard for plaintiffs to prove proximate cause in negligence cases with complex events. It highlights that negligent conduct must be a substantial factor, not just a but-for cause, to establish legal sufficiency.
For attorneys litigating personal injury and wrongful death claims — particularly those involving motor vehicle accidents — this case serves as a critical reminder to distinguish between furnishing a condition and proximately causing an injury.
The Texas Supreme Court’s ruling in this case also may have significant implications for how courts may evaluate employer liability theories (e.g., negligent hiring, training, supervision, etc.) that are derivative of an employee’s conduct. The Court held that because the employee was not a proximate cause of the plaintiffs’ injuries, his employer could not be held liable under either derivative or direct liability theories.
Even though the plaintiffs framed some claims as direct liability — arguing that Werner created an unreasonable risk by assigning an inexperienced driver to a hazardous route — the Court found these theories still hinged on Ali’s conduct. Because Ali’s actions were not a proximate cause, Werner’s direct liability claims also failed.
The ruling emphasizes that employers are not automatically liable for every negligent act of their employees. Courts must first determine whether the employee’s conduct was a proximate cause of the injury. If not, employer liability — whether framed as direct or derivative — cannot stand.
This decision may influence future litigation by narrowing the circumstances under which plaintiffs can hold employers liable for employee conduct, especially in cases involving complex chains of causation or intervening acts.