Wednesday, January 1, 2014

Union Pump Co. v. Allbritton case brief

Union Pump Co. v. Allbritton case brief summary
898 S.W.2d 773 (1995)

Petitioner manufacturer challenged a judgment from the Court of Appeals for the Ninth District of Texas, which reversed a trial court decision that had granted summary judgment to petitioner in respondent worker's action for negligence, gross negligence, and strict liability.

Respondent worker was injured when she slipped on a pipe rack that was wet because of efforts to extinguish fire in equipment made by petitioner manufacturer. Respondent brought an action against petitioner, alleging negligence, gross negligence, and strict liability.

The trial court granted petitioner summary judgment because respondent failed to demonstrate that the fire in the equipment was the cause of the injury. The court of appeals reversed and remanded the case to the trial court, holding that there were issues of fact concerning proximate cause and producing cause. Petitioner sought a writ of error challenging the judgment.

  • The court held that in order to be a legal cause of another's harm, petitioner's negligence had to have been a "substantial" factor in bringing about respondent's injury. 
  • The court held that legal cause was not established because petitioner's product did no more than create the condition that made respondent's injury possible. 
  • The court reversed the court of appeals' judgment, holding that the circumstances surrounding respondent's injuries were too remotely connected with petitioner's conduct or product to constitute a legal cause of her injuries.
The court reversed the decision of the court of appeals and rendered judgment that respondent worker take nothing because that the fire created by petitioner manufacturer's equipment was not the legal cause of the respondent's injuries.

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