Three Aces Towing, Inc. D/B/A Three Aces Storage v. Cassie Landrum, Individually, and as Personal Representative of the Estate of Jeffrey Landrum, 653 S.W.3d 727

3 Aces Towing (owned by Dawn and Robert Hancock) operates a mini-storage and contracts with General Shelters to sell storage units; General Shelters’ employee Jeffrey Landrum delivered two 8'×8' units to 3 Aces’ lot.
Landrum unloaded the first unit; for the second, the trailer rollers stuck, and he asked Dawn to help push the unit “maybe a foot” to the trailer edge, which she did.
Landrum then told Dawn to step back while he would pull and walk the unit down the ramp; Dawn retreated ~12 feet and attended to grandchildren.
The unit fell off the trailer, crushing and killing Landrum; Dawn used an excavator to lift the unit but Landrum died at the scene.
Landrum’s daughter sued 3 Aces (wrongful death/survival). The trial court granted summary judgment for 3 Aces; the court of appeals reversed in part, finding a fact issue on whether Dawn had a continuing duty; the Texas Supreme Court reversed and rendered judgment for 3 Aces.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a person who voluntarily provides limited assistance assumes a continuing duty of care after stopping	Landrum’s daughter: once Dawn joined the unloading, she undertook a duty and unreasonably withdrew assistance by stepping away; she should have warned or continued to help	3 Aces/Dawn: her help was limited to pushing the unit one foot; she stopped when Landrum told her to and did not undertake further assistance or advice	Court: any duty she undertook was limited to that discrete act and ended when she ceased helping; summary judgment for 3 Aces affirmed (court of appeals reversed)

Torrington Co. v. Stutzman, 46 S.W.3d 829 (Tex. 2000) (duty of reasonable care may arise from undertaking, but is limited to that undertaking)
Fort Bend Cnty. Drainage Dist. v. Sbrusch, 818 S.W.2d 393 (Tex. 1991) (same principle on limits of undertaking liability)
Elephant Ins. Co. v. Kenyon, 644 S.W.3d 137 (Tex. 2022) (existence of legal duty is a question of law)
Colonial Sav. Ass’n v. Taylor, 544 S.W.2d 116 (Tex. 1976) (duty principles governing negligent undertakings)
Kuentz v. Cole Sys. Grp., Inc., 541 S.W.3d 208 (Tex. App.—Houston [14th Dist.] 2017) (undertaking limited to discrete tasks defeats negligent-undertaking claim)
Knife River Corp.–S. v. Hinojosa, 438 S.W.3d 625 (Tex. App.—Houston [1st Dist.] 2014) (scope of contractor’s undertaking determines liability)