Hyde v. HOERAUF, 337 S.W.3d 431

Brandi Ross, a minor, died in a car crash after leaving a pasture party on land owned by Hoerauf in Henderson County.
Party attendees were trespassers; no one at the party had Hoerauf’s permission to be on the property.
Hoerauf had prior fence-cutting incidents and began constructing heavy fencing, unaware of the specific teen gathering.
Hyde sued for wrongful death and survival, alleging negligence and gross negligence by Hoerauf and related entities.
Hoerauf moved for summary judgment; Hyde argued there were material fact questions about notice and foreseeing risk from minors drinking.
The trial court granted summary judgment for Hoerauf; the court of appeals upheld, focusing on off-premises injury and lack of duty.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether absent landowner owes duty to trespasser off premises	Hyde asserts Hoerauf knew of trespass issues and should have foreseen harm from alcohol use by minors.	Hoerauf had no control over the off-premises injury and owed no duty to trespassers once they left the property.	No duty to trespassers off premises; affirm summary judgment.

Gen. Elec. Co. v. Moritz, 257 S.W.3d 211 (Tex. 2008) (premises liability duty exists only for injury on the premises)
Graff v. Beard, 858 S.W.2d 918 (Tex. 1993) (existence of legally cognizable duty prerequisite to tort liability)
City of Denton v. Page, 701 S.W.2d 831 (Tex. 1986) (possession/control prerequisite to premises liability duty)
Wilson v. Texas Parks & Wildlife Dep't, 8 S.W.3d 634 (Tex. 1999) (injury must occur on premises owned or controlled to impose duty)
Olivo v. Clayton W. Williams, Jr., Inc., 952 S.W.2d 523 (Tex. 1997) (duty relates to control of the premises and the condition causing injury)
Dixon v. Houston Raceway Park, Inc., 874 S.W.2d 760 (Tex. App.-Houston (1st Dist.) 1994) (premises owner has no duty for injuries on adjacent highways)