U-Haul International, Inc. v. Waldrip
380 S.W.3d 118
| Tex. | 2012Background
- Waldrip was seriously injured when a U-Haul jumbo hauler rolled backward as he exited; the truck allegedly failed due to parking-brake and transmission problems.
- The trial focused on UHI/UHT maintenance and inspection programs, including PM-5 inspections, safety certifications, and the R&D tag system, plus a DET database tracking downed equipment.
- Waldrip argued chronic failures in inspection/maintenance caused the accident; U-Haul disputed, blaming proper procedures and external factors.
- JH6097T had inoperable parking brake and damaged transmission; prior reports and certifications showed multiple maintenance issues over 2005–2006.
- Evidence showed DOT/annual inspections and safety-certifications schedules, and that some AFMs (non-mechanics) conducted inspections with limited training.
- The jury awarded compensatory damages and punitive damages; the court of appeals partially affirmed, reversing some exemplary damages and the gross-negligence ruling, leading to review by the Texas Supreme Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Canadian evidence was admissible and its effect on verdict | Waldrip argues Patterson’s Canadian inspections show systemic safety disregard | U-Haul argues evidence was irrelevant, prejudicial, and improperly admitted | Abuse of discretion; probable harm to verdict; remand for negligent claims only |
| Whether Patterson’s testimony proper to prove a fleet-wide maintenance pattern | Waldrip contends pattern evidence shows systemic failure | U-Haul contends evidence lacks similarity and is prejudicial | No; evidence not sufficiently similar to JH6097T to prove system-wide disregard |
| Whether there was legally sufficient evidence of gross negligence against UHI | Waldrip asserts conscious indifference evidenced by DET data and Canadian studies | UHI argues no actual knowledge or managerial likelihood of risk | No clear and convincing evidence of gross negligence against UHI |
| Whether there was legally sufficient evidence of gross negligence against UHT | Waldrip argues Buck’s reckless hiring of Crews shows gross negligence | Buck’s beliefs about training negate conscious indifference; Moriel standard limits liability | Insufficient proof of Buck’s conscious indifference; gross-negligence claim against UHT not supported |
| Whether the judgment should be remanded for a new trial on negligence claims | Residual error from admissible evidence; proper remedy is remand | Errors were harmless or not pivotal to fault findings | Remand for new trial on negligence against all defendants; take-nothing on gross-negligence against UHI and UHT |
Key Cases Cited
- Nissan Motor Co., Ltd. v. Armstrong, 145 S.W.3d 131 (Tex. 2004) (admissibility and similarity required for prior-incident databases)
- Serv. Corp. Int'l v. Guerra, 348 S.W.3d 221 (Tex. 2011) (admissibility limits for other suits as pattern evidence; not to prove conduct in conformity with prior acts)
- Hammerly Oaks, Inc. v. Edwards, 958 S.W.2d 387 (Tex. 1997) (restatement-based imputing gross negligence to corporations; managerial-vice-principal concept)
- Moriel v. Trans. & Leasing, Inc., 879 S.W.2d 10 (Tex. 1994) (standard for punitive damages; actionable gross negligence requires conscious indifference)
- Moriel, 879 S.W.2d 10 (Tex. 1994) (clarifies exceptional nature of punitive damages and conscious indifference)
- Reliance Steel & Aluminum Co. v. Sevcik, 267 S.W.3d 867 (Tex. 2008) (harmful-evidence review; factors for assessing prejudice and impact on verdict)
- Guerra, 348 S.W.3d 221 (Tex. 2011) (admission of other lawsuits; pattern evidence; impact on damages verdict)