TX Nuclear Verdict Overturned

The Texas Supreme Court on June 27, 2025 reversed a $90 million jury verdict (originally ~$89.7 M from 2018 and later ~ $100 M with interest) against Werner Enterprises and its driver for a 2014 crash on icy Interstate 20 near Odessa TX. The collision occurred when a pickup, driven too fast for icy conditions, lost control, crossed a 42‑foot median, and struck Werner’s tractor-trailer, killing one passenger and severely injuring others.

While a jury had put most fault on the truck, the Texas Supreme Court found the evidence legally insufficient to show Werner’s negligence was a substantial factor in causing the crash. Chief Justice Blacklock emphasized the sole proximate cause was the pickup’s sudden loss of control—not anything the Werner driver did. The court therefore reversed and rendered judgment for Werner, though one dissent argued a new trial was warranted.

Back to Basics of Tort Law: Four Prongs of Negligence

To determine negligence, courts focus on these four foundational elements. Each must be independently and firmly established:

1. Duty – Did Werner owe a duty to the injured parties?

2. Breach – Did Werner or its driver fail to meet that duty?

3. Causation – Did that breach substantially cause the harm?

4. Damages – Did actual losses occur as a result?

In this case, while duty and breach might have been arguable—such as a trainee driving in icy conditions—the crucial battleground was causation. Procedurally, the court required that Werner’s breach be shown to be a substantial factor in bringing about the injuries. The court found only the pickup’s loss of control met that threshold.

Why Causation Matters

• Proximate cause isn't about slight contributions—it demands the defendant’s actions be a meaningful cause of the injury.

• Even if Werner's driver had been negligent (e.g., inappropriate speed), if the accident still would have occurred (because another driver lost control), causation fails.

• The Texas Supreme Court emphasized this point—Werner’s brake and lane discipline didn’t substantially cause the accident.

The Texas Supreme Court’s reversal reinforces a core tort principle: Meeting duty or breach is only half the battle—without solid causation, liability collapses. Returning to the basic four-pronged negligence analysis ensures clarity, precision, and fairness in outcomes—particularly in high-stakes (or “nuclear”) verdicts.