Werner Enterprises, Inc. and Shiraz A. Ali v. Jennifer Blake, Individually and as Next Friend for Nathan Blake, and as Heir of the Estate of Zackery Blake, Deceased; And Eldridge Moak, in His Capacity as Guardian of the Estate of Brianna Blake, 719 S.W.3d 525

The case arises from a collision in icy conditions on a Texas interstate, in which a vehicle lost control, crossed the median, and collided with a Werner Enterprises truck driven by Shiraz Ali.
Ali had driven past multiple icy-weather accidents prior to the crash and was traveling at about 50 mph when the other vehicle crossed into his path.
The plaintiffs (Blake et al.) argued that Ali was driving too fast for the conditions and that his speed contributed to the severity of their injuries.
The jury found Werner Enterprises and Ali mostly responsible for the injuries, assigning them 84% of the fault; the trial court entered judgment on this basis.
The Supreme Court reviewed the case, focusing on whether Ali's speed was a proximate cause of the injuries and if the jury instructions correctly stated the law regarding causation and apportionment of responsibility.
The dissent agreed with reversing the trial judgment, but would have remanded for a new trial due to harmful jury charge errors, rather than rendering judgment for Werner and Ali.

Issue	Blake's Argument	Werner/Ali's Argument	Held
Proximate Cause – Ali’s Speed	Excessive speed in icy conditions contributed to the injuries’ severity	Ali’s speed was not a substantial factor; accident unforeseeable	Some evidence supports proximate cause, jury should decide
Foreseeability	A prudent driver should foresee loss of control by others in icy conditions	Could not foresee such a collision scenario	Sufficient evidence for jury on foreseeability
Duty to Reduce Speed in Icy Conditions	Duty exists to lower speed for safety when roads are icy	No special duty; can't be responsible for unforeseeable events	Statutory and common law duties require prudent speed
Faulty Jury Instructions/Direct Liability	Instructions wrongly allowed liability on erroneous/overbroad theories	Agreed; error to submit certain instructions	Error required reversal; dissent favors new trial

Lear Siegler, Inc. v. Perez, 819 S.W.2d 470 (Tex. 1991) (proximate cause must not be too attenuated; mere creation of a condition is insufficient)
Union Pump Co. v. Allbritton, 898 S.W.2d 773 (Tex. 1995) (causation requires more than establishing a condition existed)
IHS Cedars Treatment Ctr. of DeSoto, Tex., Inc. v. Mason, 143 S.W.3d 794 (Tex. 2004) (proximate cause requires cause-in-fact and foreseeability)
Nabors Well Services, Ltd. v. Romero, 456 S.W.3d 553 (Tex. 2015) (proportionate responsibility includes all conduct contributing to injury in any way)
Lofton v. Texas Brine Corp., 777 S.W.2d 384 (Tex. 1989) (foreseeability does not require anticipating exact sequence of injury events)