Ryder Integrated Logistics, Inc. v. Fayette County, Texas, 453 S.W.3d 922

Ryder Integrated Logistics, Inc. sues Fayette County under the TTCA for injuries arising from a collision involving a deputy’s vehicle.
The collision occurred on I-10 during a routine traffic stop near a deputy sheriff who was repositioning his cruiser.
Ryder alleges the deputy’s headlights blinded the other driver, contributing to the crash.
Molina, the truck driver stopped for a minor violation, died in the fire from the crash.
The County filed a plea to the jurisdiction arguing no TTCA waiver because the injury did not arise from vehicle use.
The trial court and court of appeals agreed; the Supreme Court reversed, holding the injury arose from vehicle use.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ryder alleged injury arising from vehicle use under §101.021(1)(A)	Ryder alleges Thumann operated the cruiser, including moving it toward oncoming traffic.	County argues the use was not the negligent act but only a setting/condition.	Yes; waiver applies because there is a nexus to vehicle use.
Whether Thumann’s conduct can constitute proximate cause	Thumann’s operation and headlights proximately caused Solis’s driving error.	The County contends the act is too attenuated to be proximate cause.	Proximate-cause question factual; sufficient to create a fact issue.
Whether Solis’s alleged Move Over Act violation forecloses liability	Solis violated the law but the statute applied only to stationary vehicles.	Move Over Act precludes liability under certain circumstances.	Move Over Act not applicable here; not dispositive.
Whether the plaintiff’s own conduct precludes recovery under comparative fault	Dugger framework allows recovery despite plaintiff’s conduct.	Proportionate liability governs recovery.	Plaintiff may recover proportionately; no per se bar.

Dall. Area Rapid Transit v. Whitley, 104 S.W.3d 540 (Tex. 2003) (defines TTCA vehicle-use nexus and standard for arising from)
LeLeaux v. Hamshire–Fannett Indep. Sch. Dist., 835 S.W.2d 49 (Tex. 1992) (limits immunity waiver to active vehicle use)
Miranda v. Tex. Parks & Wildlife, 133 S.W.3d 217 (Tex. 2004) (liberal pleading standard for jurisdictional review)
State v. Terrell, 588 S.W.2d 784 (Tex. 1979) (policies-based liability for negligent government conduct)
Bossley v. Dallas Cnty. Mental Health & Mental Retardation, 968 S.W.2d 339 (Tex. 1998) (attenuation standard for causation in TTCA context)
Del Lago Partners, Inc. v. Smith, 307 S.W.3d 762 (Tex. 2010) (proximate cause framework in Texas)
Utica Nat’l Ins. Co. v. Am. Indem. Co., 141 S.W.3d 198 (Tex. 2004) (proximate cause analysis in insurance/TTCA)
Nabors Drilling, U.S.A., Inc. v. Escoto, 288 S.W.3d 401 (Tex. 2009) (definition of negligence for TTCA pleadings)
Dugger v. Arredondo, 408 S.W.3d 825 (Tex. 2013) (abrogated all-or-nothing contributory approach; proportionate liability)
Grisham v. Texas Dept. of Public Safety, 232 S.W.3d 822 (Tex. App.—Houston [14th Dist.] 2007) (whether emergency lights alone render a parked cruiser in use)
Hernandez v. City of Lubbock, 253 S.W.3d 750 (Tex. App.—Amarillo 2007) (illustrates police officer liability in proper context)