Garcia v. San Antonio Housing Authority

859 S.W.2d 78, 1993 Tex. App. LEXIS 2508, 1993 WL 231674
CourtCourt of Appeals of Texas
DecidedJune 23, 1993
Docket04-91-00708-CV
StatusPublished
Cited by20 cases

This text of 859 S.W.2d 78 (Garcia v. San Antonio Housing Authority) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia v. San Antonio Housing Authority, 859 S.W.2d 78, 1993 Tex. App. LEXIS 2508, 1993 WL 231674 (Tex. Ct. App. 1993).

Opinions

ON APPELLANT’S MOTION FOR REHEARING

PEEPLES, Justice.

Our previous opinion of March 3, 1993, is withdrawn and replaced by the following opinion.

In this case we must decide whether Ruben Garcia, an uncle who witnessed his nephew’s injury, may recover for his own mental anguish as a bystander. We hold that neither a close personal relationship nor the uncle-nephew relationship without more is sufficient for recovery as a bystander. But we conclude that a relative residing in the injured person’s household may recover as a bystander, and we therefore reverse the take-nothing summary judgment.

Ruben brought suit against the San Antonio Housing Authority and six other defendants to recover for mental anguish he suffered when he rescued his nephew Adrian from a fire in the apartment where Adrian and his family lived. Adrian’s suit by next friend for his own injuries is not part of this appeal. The trial court rendered a take-nothing summary judgment against Ruben on the ground that an uncle has no standing to seek mental anguish damages as a bystander for injuries suffered by a nephew.1 Ruben argues that he should be able to recover because he has a close personal relationship with his nephew and is a father figure who lived with the family and who eyewitnessed his nephew’s injury and suffering.

Bystander recovery for mental anguish first gained impetus with the decision in Dillon v. Legg, 68 Cal.2d 728, 69 Cal.Rptr. 72, 441 P.2d 912 (1968). There the court allowed a mother to recover for mental anguish she suffered upon witnessing the death of her child. The Dillon court contemplated that courts would determine duty case-by-case after considering three guidelines:

(1) Whether plaintiff was located near the scene of the accident as contrasted [80]*80with one who was a distance away from it. (2) Whether the shock resulted from a direct emotional impact upon plaintiff from the sensory and contemporaneous observance of the accident, as contrasted with learning of the accident from others after its occurrence. (3) Whether plaintiff and the victim were closely related, as contrasted with an absence of any relationship or the presence of only a distant relationship.2

Id. 69 Cal.Rptr. at 80, 441 P.2d at 920. The Texas courts adopted Dillon in 1978, calling it the “modern rule.” See Landreth v. Reed, 570 S.W.2d 486, 489 (Tex.App.—Texarkana 1978, no writ). The supreme court has accepted the Dillon guidelines while denying recovery to a stepparent who “did not contemporaneously perceive the accident or otherwise experience the shock of unwittingly coming upon the accident scene.” Freeman v. City of Pasadena, 744 S.W.2d 923, 924 (Tex.1988). The court later denied recovery for mental anguish to a child who was not at or near the scene where the parent was injured and who did not suffer “direct emotional impact ... from the sensory and contemporaneous observance of the incident, as contrasted with learning of the accident from others” afterward. Reagan v. Vaughn, 804 S.W.2d 463, 467 (Tex.1990). The court has again stated its adherence to Dillon while holding there is no general cause of action for negligent infliction of emotional distress. Boyles v. Kerr, 855 S.W.2d 593, 597-598 (Tex.1993).3 Freeman and Reagan show that even the parent-child relationship will not support a mental-anguish recovery if the plaintiff was not a bystander within Dillon.

Unlike the plaintiffs in Freeman and Reagan, Ruben Garcia clearly satisfies the first two Dillon factors: he was at the scene and he suffered direct emotional impact from observing the incident firsthand. But the third factor requires a close relationship between the bystander and the injured person, and his relationship to his nephew is biologically distant.

Our courts have denied bystander recovery when the plaintiff had no formal or biological relationship to the injured person. In Hinojosa v. South Texas Drilling & Exploration, Inc., 727 S.W.2d 320 (Tex.App.—San Antonio 1987, no writ), plaintiff had heard his co-worker and close friend fall to his death and land near the area where plaintiff was working. We denied recovery because there was no familial relationship. In Hastie v. Rodriguez, 716 S.W.2d 675 (Tex.App.—Corpus Christi 1986, writ ref’d n.r.e.), the plaintiff was a live-in girl friend who witnessed an accident involving her male partner. Plaintiff did not establish common-law marriage, and the court denied recovery because there was no familial relationship. In Genzer v. City of Mission, 666 S.W.2d 116 (Tex.App.—Corpus Christi 1983, writ ref’d n.r.e.), the plaintiffs were the grandparents of a child who was injured and died. The court permitted recovery, noting that the grandparents had a close relationship with the child.

These cases illustrate that in Texas the Dillon requirement of a plaintiff “closely related” to the victim requires a familial relationship of some sort; it is not enough to show a close non-familial rela[81]*81tionship, or a distant familial relationship without more. That the relationship must be familial is shown by a recent California Supreme Court decision authored by Justice Mosk, a member of the Dillon majority. In Elden v. Sheldon, 46 Cal.3d 267, 250 Cal.Rptr. 254, 758 P.2d 582 (1988), the plaintiff had witnessed the tortious injury and death of the woman with whom he had cohabited, whom he termed his “de facto spouse.”4 The court held that the plaintiff did not meet the third Dillon requirement — a close relationship. This requirement excludes “friends or distant relatives of the injured person,” such as first cousins, and close girl friends who are akin to natural sisters. Id. 250 Cal.Rptr. at 256, 758 P.2d at 584. The court disapproved the notion that it is the emotional attachment that counts, not the biological or marital relationship. Id. 250 Cal.Rptr. at 256-61, 758 P.2d at 584-88.5

The question here is whether the uncle-nephew relationship is enough to justify bystander recovery. To require mere emotional “closeness” would require constant ad hoc line-drawing; courts would have to probe case-by-case the genuineness of the relationship. Presumably when several people were injured, courts would weigh the varying relationships and decide which ones were close enough to justify bystander recovery and which ones were not. We question whether it is in society’s interest for courts and litigants to delve into family relationships to this extent. See Elden v. Sheldon, 250 Cal.Rptr. at 259, 758 P.2d at 587. And courts must draw a line somewhere.

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Bluebook (online)
859 S.W.2d 78, 1993 Tex. App. LEXIS 2508, 1993 WL 231674, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-san-antonio-housing-authority-texapp-1993.