Allways Auto Group, Ltd. D/B/A Atascosa Chrysler Dodge Jeep Ram v. Steven Walters
530 S.W.3d 147
| Tex. | 2017Background
- Allways Auto Group (dealer) provided a 2012 Dodge Ram loaner to William Heyden when his newly purchased 2008 Dodge Caliber was taken in for repairs.
- Heyden had no license in his possession (presented a photocopy), had recent prior DWI citations, and had surrendered his Texas license after refusing a breathalyzer; Allways did not investigate his criminal history.
- Heyden received the loaner after allegedly being intoxicated at the dealership, though the salesman said he did not appear impaired. Repairs were delayed, and Heyden kept the loaner for 18 days.
- Eighteen days later Heyden, heavily intoxicated (BAC ≥ .147), crossed the center line on a bridge and crashed into Steven Walters’s pickup; Heyden later claimed suicidal intent and was convicted of intoxication assault and DWI.
- Walters sued Allways for negligent entrustment; the trial court granted summary judgment for Allways on proximate-cause/attenuation grounds, the court of appeals reversed, and the Texas Supreme Court granted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether providing the loaner was a proximate cause of Walters’s injuries | Walters: loaning the vehicle enabled Heyden’s later intoxicated driving and thus was a legal cause | Allways: the 18‑day gap and intervening events make the causal link too attenuated to be legal cause | Held for Allways: entrustment was not proximate cause because the connection was too attenuated |
Key Cases Cited
- Schneider v. Esperanza Transmission Co., 744 S.W.2d 595 (Tex. 1987) (entrustment is a proximate cause only if injury is a natural and probable consequence of entrustment)
- Union Pump Co. v. Allbritton, 898 S.W.2d 773 (Tex. 1995) (legal cause may fail where the defendant’s conduct merely furnishes a condition that makes injury possible)
- IHS Cedars Treatment Ctr. of DeSoto, Tex., Inc. v. Mason, 143 S.W.3d 794 (Tex. 2004) (discussing limits of proximate cause and attenuation)
- Lear Siegler, Inc. v. Perez, 819 S.W.2d 470 (Tex. 1991) (legal-cause principles and attenuation analysis)
- Bell v. Campbell, 434 S.W.2d 117 (Tex. 1968) (early statement that causal connection can be too attenuated to impose liability)
