Robert Nicholas Donahue v. Polaris Industries, Inc.

CourtCourt of Appeals of Texas
DecidedMarch 29, 2012
Docket02-11-00279-CV
StatusPublished

This text of Robert Nicholas Donahue v. Polaris Industries, Inc. (Robert Nicholas Donahue v. Polaris Industries, Inc.) 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
Robert Nicholas Donahue v. Polaris Industries, Inc., (Tex. Ct. App. 2012).

Opinion

02-11-279-CV

COURT OF APPEALS

SECOND DISTRICT OF TEXAS

FORT WORTH

NO. 02-11-00279-CV

Robert Nicholas Donahue

APPELLANT

V.

Polaris Industries, Inc.

APPELLEE

----------

FROM THE 431st District Court OF Denton COUNTY

MEMORANDUM OPINION[1]

          Appellant Robert Nicholas Donahue appeals the trial court’s summary judgment in favor of appellee Polaris Industries, Inc.  We will affirm.

Background Facts

          Polaris makes all-terrain vehicles (ATVs).  In 2007, Polaris contracted with a team of professional ATV stuntmen known as Bomb Squad, Inc. to promote Polaris vehicles.  Bomb Squad describes itself as an “ATV freestyle team . . . comprised of the top riders in the world.”  Bomb Squad performs in “powersport” competitions and makes stunt videos distributed by H-Bomb Films, Inc.  Bomb Squad trains and films in a facility located in Krum, Texas, operated by Bomb Squad team member Caleb Moore.  Under the terms of the promotion contract, Polaris provided Bomb Squad with nine ATVs.  The contract stated that Polaris would transfer title to the ATVs to Bomb Squad at the expiration of the contract provided that Bomb Squad performed its promotional duties.  Those duties included participating in ATV races, photo and video sessions for Polaris marketing material, and product demonstrations.

          In August 2008, Bomb Squad offered Donahue an opportunity to audition for membership on the team.  Although Donahue “had some experience riding ATVs,” he had no experience with difficult stunts.  He accepted the opportunity because he “knew [Bomb Squad was] on the cutting edge for free style ATV.”  Donahue flew from his home in New Jersey to the Krum facility for the audition.  At the facility, Moore gave Donahue one of the Polaris ATVs and told Donahue to perform a back flip on the ATV by riding up a ramp over a pit filled with foam rubber.  Moore did not question Donahue about his experience or skill level before asking Donahue to perform the stunt, nor did he or any other Bomb Squad member ask Donahue to demonstrate more basic skills before the jump.

          Donahue’s first attempt at the back flip failed, but he landed safely in the pit.  Moore gave Donahue some instruction on how to flip the ATV, and Donahue tried again.  The second time, Donahue failed, and the ATV fell on top of him, breaking his neck and rendering him a quadriplegic.

          Donahue sued Polaris, Bomb Squad, H-Bomb Films, and Moore, among others.  Against Polaris, Donahue asserted claims of joint enterprise and negligent entrustment and a cause of action under section 390 of the Restatement (Second) of Torts.[2]  Polaris filed for summary judgment on Donahue’s causes of action against it, which the trial court granted.  Polaris was severed from the case, and this appeal followed.

Standard of Review

          We review a summary judgment de novo.  Travelers Ins. Co. v. Joachim, 315 S.W.3d 860, 862 (Tex. 2010).  We consider the evidence presented in the light most favorable to the nonmovant, crediting evidence favorable to the nonmovant if reasonable jurors could, and disregarding evidence contrary to the nonmovant unless reasonable jurors could not.  Mann Frankfort Stein & Lipp Advisors, Inc. v. Fielding, 289 S.W.3d 844, 848 (Tex. 2009).  We indulge every reasonable inference and resolve any doubts in the nonmovant’s favor.  20801, Inc. v. Parker, 249 S.W.3d 392, 399 (Tex. 2008).  A defendant who conclusively negates at least one essential element of a cause of action is entitled to summary judgment on that claim.  Frost Nat’l Bank v. Fernandez, 315 S.W.3d 494, 508 (Tex. 2010); see Tex. R. Civ. P. 166a(b), (c).

Discussion

Because Donahue did not challenge summary judgment on his joint enterprise claim against Polaris in the trial court or on appeal, we address only Donahue’s negligent entrustment claim and his cause of action under the Restatement of Torts.

In his first issue, Donahue argues that summary judgment was improper on his claim of negligent entrustment against Polaris.  To establish liability for negligent entrustment, Donahue must show that:  (1) Polaris entrusted the vehicle to Bomb Squad; (2) Bomb Squad was an unlicensed, incompetent, or reckless driver; (3) at the time of the entrustment, Polaris knew or should have known that Bomb Squad was an unlicensed, incompetent, or reckless driver; (4) Bomb Squad was negligent on the occasion in question; and (5) Bomb Squad’s negligence proximately caused the accident.  Goodyear Tire & Rubber Co. v. Mayes, 236 S.W.3d 754, 758 (Tex. 2007) (citing Schneider v. Esperanza Transmission Co., 744 S.W.2d 595, 596 (Tex.1987)).  The negligent entrustment must also be a proximate cause of the injury.  Schneider, 744 S.W.2d at 596.  “For entrustment to be a proximate cause, the defendant entrustor should be shown to be reasonably able to anticipate that an injury would result as a natural and probable consequence of the entrustment.”  Id.

In Schneider, the defendant company provided a truck to its employee, Havelka, for business and personal use.  Id.

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Related

Goodyear Tire and Rubber Co. v. Mayes
236 S.W.3d 754 (Texas Supreme Court, 2007)
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Newkumet v. Allen
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Schneider v. Esperanza Transmission Co.
744 S.W.2d 595 (Texas Supreme Court, 1987)
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Robert Nicholas Donahue v. Polaris Industries, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-nicholas-donahue-v-polaris-industries-inc-texapp-2012.