On June 27, 2025, the Texas Supreme Court issued its opinion in Werner Enterprises, Inc. v. Blake, No. 23-0493, providing significant guidance on the doctrine of proximate cause in Texas negligence law. The Court reversed a multimillion-dollar judgment against Werner Enterprises and its driver, holding that the defendants’ conduct was not a substantial factor in causing the plaintiffs’ injuries, and that the sole proximate cause was the loss of control by a third-party driver. This decision is important for transportation companies, insurers, and litigators handling catastrophic accident cases in Texas.

Factual Background

Blake involved a tragic highway collision near Odessa, Texas. On that afternoon, Trey Salinas was driving his F-350 pickup truck eastbound on Interstate 20 with Jennifer Blake and her three children as passengers. The National Weather Service had issued a winter weather advisory earlier that day, warning of hazardous icy conditions, and by the time of the accident, the roads were covered in ice and multiple accidents had already occurred in the area.

As Salinas drove at approximately 50-60 miles per hour, he lost control of his pickup on the icy road. In just two to three seconds, the F-350 left the eastbound lanes, crossed a 42-foot-wide grassy median, and entered the westbound lanes, where it collided with a Werner Enterprises 18-wheeler driven by Shiraz Ali. Ali, a driver in training, was traveling below the posted speed limit but at a speed that was later alleged to be unsafe for the conditions. Ali’s trainer was in the sleeper berth at the time. Ali testified that he reacted as soon as he saw the pickup, pressing the brake as hard as he could, and the plaintiffs’ expert agreed that Ali’s reaction was appropriate given the circumstances. Despite this, the collision was catastrophic: one of the Blake children was killed, and the other three family members suffered severe injuries, including permanent quadriplegia and traumatic brain injuries.

Evidence at trial established that Ali had not checked the weather before driving that stretch of highway and was unaware of the most recent advisories. He had passed several accidents in the hour before the collision but did not recall seeing them. Data showed that Ali’s speed averaged over 60 miles per hour in the hours leading up to the crash, and he was accelerating just before the accident. At the moment of impact, the 18-wheeler was traveling approximately 43-45 miles per hour. The entire sequence — from Salinas losing control to the collision — lasted about two seconds.

The plaintiffs sued Werner and Ali, alleging that Ali’s unsafe speed and Werner’s training and supervision practices were negligent and proximately caused the injuries. The jury found Werner and Ali liable, apportioning 70% of the responsibility to Werner employees other than Ali, 14% to Ali, and 16% to Salinas, and awarded substantial damages, including $16.5 million for Jennifer Blake, $5 million for Nathan Blake, and $68,187,994 for Brianna Blake.

Werner and Ali appealed, challenging the sufficiency of the evidence on negligence and causation, among other issues.

Key Holdings

• Proximate Cause Requires a Substantial Factor: The Court held that, even if Ali’s speed was negligent and a “but-for” cause of the accident, it was not a substantial factor in bringing about the injuries. The “sole proximate cause” was Salinas’ loss of control and sudden entry into oncoming traffic, which left Ali no time to react.
• Negligence Must Be More Than a “Happenstance of Place and Time”: The Court emphasized that liability does not attach to a party whose conduct merely furnishes the condition that makes an injury possible, but only to those whose conduct is actually responsible for the ultimate harm.
• No Derivative or Direct Employer Liability: Because Ali’s conduct was not a proximate cause, all claims against Werner, whether based on direct or derivative theories (such as negligent training or supervision), also failed as a matter of law.

Takeaways

• The decision provides a strong precedent for challenging liability in cases where a defendant’s conduct is merely a condition, not a substantial factor, in causing an accident.
• Employers cannot be held liable on direct or derivative negligence theories if the employee’s conduct is not a proximate cause of the injury.
• The opinion reinforces the importance of focusing on proximate cause and the substantial factor test in defending catastrophic accident litigation.

Conclusion

The Texas Supreme Court’s decision in Werner Enterprises, Inc. v. Blake clarifies the limits of proximate cause in Texas negligence law and provides important guidance for future accident litigation. Defendants whose conduct is merely a “happenstance of place and time” rather than a substantial factor in causing harm may have a strong basis for summary judgment or reversal on appeal.