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, 23-0493

In December 2014, a catastrophic accident occurred on an icy, divided Texas interstate when a pickup truck lost control, crossed a wide median, and struck a Werner Enterprises 18-wheeler driven by Shiraz Ali.
The collision killed one Blake child and severely injured three others; the family sued Werner and Ali for negligence.
Weather conditions were hazardous; several earlier accidents had occurred in the area due to ice, and some 18-wheelers had chosen to pull off the highway.
The plaintiffs argued Ali was driving too fast for the icy conditions, though still below the speed limit, and that Werner was negligent in training/supervising Ali.
The jury apportioned liability between Werner, Ali, and the pickup driver (Salinas), awarding large damages; Werner and Ali appealed, arguing, among other things, that their actions did not proximately cause the accident.
The Texas Supreme Court rendered judgment for Werner and Ali, reversing the lower court and jury findings, on the ground that the accident’s sole proximate cause was Salinas losing control and crossing the median.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Was Ali’s speed a proximate cause of the injuries?	Ali’s unsafe driving in icy conditions was a substantial factor in causing or worsening the injuries.	Ali’s speed merely created the condition; the sole proximate cause was Salinas's loss of control.	No proximate cause; sole cause was Salinas’s vehicle losing control and crossing the median.
Can Werner be held liable for negligent training/supervision?	Werner negligently trained/supervised Ali, contributing to the accident.	Werner’s liability is derivative; no liability if Ali not proximately liable.	No employer derivative liability since Ali was not a proximate cause.
Does substantial-factor causation apply?	Ali’s presence and speed were substantial factors under but-for and foreseeability tests.	Substantial-factor requires more than but-for causation; responsibility lies only with true cause.	Substantial-factor test not met; Ali’s actions too attenuated to be a cause-in-fact.
Does precedent (e.g., Biggers) require finding for the plaintiffs?	Similar cases found foreseeability and proximate cause where a vehicle left its lane.	Biggers factually distinct; divided highways are not analogous to two-lane roads.	Biggers distinguishable; rule does not extend to divided highways like here.

Lear Siegler, Inc. v. Perez, 819 S.W.2d 470 (Tex. 1991) (explains substantial-factor causation and responsibility in proximate cause)
Transcon. Ins. Co. v. Crump, 330 S.W.3d 211 (Tex. 2010) (details proximate cause and substantial factor requirements)
IHS Cedars Treatment Ctr. of DeSoto, Tex., Inc. v. Mason, 143 S.W.3d 794 (Tex. 2004) (distinguishes causation in fact from furnishing a condition)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (outlines standard for reviewing jury verdicts)
Pediatrics Cool Care v. Thompson, 649 S.W.3d 152 (Tex. 2022) (summarizes causation standards)
Stanfield v. Neubaum, 494 S.W.3d 90 (Tex. 2016) (clarifies when furnishing a condition is not causation in fact)
Biggers v. Continental Bus System, Inc., 303 S.W.2d 359 (Tex. 1957) (compares foreseeability and proximate cause in highway collisions)
Baumler v. Hazelwood, 347 S.W.2d 560 (Tex. 1961) (focuses on reaction time and proximate cause on highways)