Tristina Guidry v. National Freight, Inc.

CourtCourt of Appeals of Texas
DecidedMay 1, 1997
Docket03-96-00451-CV
StatusPublished

This text of Tristina Guidry v. National Freight, Inc. (Tristina Guidry v. National Freight, 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
Tristina Guidry v. National Freight, Inc., (Tex. Ct. App. 1997).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-96-00451-CV

Tristina Guidry, Appellant


v.



National Freight, Inc., Appellee



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 353RD JUDICIAL DISTRICT

NO. 95-02062-A, HONORABLE F. SCOTT McCOWN, JUDGE PRESIDING

Appellant Tristina Guidry appeals the trial court's summary judgment in favor of appellee National Freight, Inc. ("National"). In two points of error, Guidry asserts the trial court erred by granting National's motion for summary judgment and severing National from the original group of defendants in her negligence claim. We will affirm the judgment of the trial court.

BACKGROUND

The background facts surrounding this case are known through the confession and subsequent criminal prosecution of Alberto Jaramillo, a long-haul truck driver employed by National, whose actions form the basis of Guidry's negligence claim against National. Jaramillo stated in his 1992 employment application for National that he had no criminal record, but National never confirmed Jaramillo's statement. In fact, Jaramillo had a history of sexual misconduct contained within his military records, criminal records, and previous employment records. National checked the driving record of Jaramillo as required by law but never conducted an independent investigation into his non-vehicular criminal past. National did not obtain verbal or written information on Jaramillo from his last employer. (1)

While driving through Austin, around 2:00 a.m. on February 23, 1993, Jaramillo stopped and parked his National truck at the Internal Revenue Service building in Austin to urinate and stretch his legs. Leaving his truck in the parking lot, he wandered through an adjacent neighborhood and eventually into the parking lot of the Timber Ridge III condominiums. Meanwhile, Guidry was returning home from a University of Texas library. Jaramillo approached Guidry in the parking lot and proceeded to drag her to an adjoining apartment complex, assault her, and rape her. Jaramillo wore no clothing representative of a National employee; he was not in the course of hauling or delivering anything to her or the apartment complex where she lived or was assaulted, and National's truck was not used in the attack.

Guidry sued numerous defendants, including National, for personal injury damages resulting from the sexual assault. She alleged that National was liable for the negligent hiring, supervision, and retention of Jaramillo. National filed a motion for summary judgment on the grounds that it owed no duty to Guidry and, in the alternative, that National's actions were not the proximate cause of Guidry's injuries. The trial court granted National's motion for summary judgment, severed Guidry's claim against National from the remaining defendants, and rendered final judgment in favor of National. Guidry appeals.



DISCUSSION

The standards for reviewing a summary judgment are well established: (1) the movant for summary judgment has the burden of showing there is no genuine issue of fact and that it is entitled to summary judgment as a matter of law; (2) in deciding whether there is a disputed fact issue precluding summary judgment, evidence favorable to the non-movant will be taken as true; and (3) every inference must be indulged in favor of the non-movant and any doubts resolved in its favor. Nixon v. Mr. Property Management Co., 690 S.W.2d 546, 548-49 (Tex. 1985). The function of summary judgment is not to deprive litigants of the right to trial by jury but to eliminate nonmeritorious claims and defenses. See Gulbenkian v. Penn, 252 S.W.2d 929, 931 (Tex. 1952). Because the district court granted summary judgment in a general order, we must affirm the judgment if it is supported by either of the legal grounds presented in National's motion. See State Farm Fire & Cas. Co. v. S. S., 858 S.W.2d 374, 380 (Tex.1993); Rogers v. Ricane Enters., Inc., 772 S.W.2d 76, 79 (Tex.1989). We review de novo the district court's determination that National was entitled to judgment as a matter of law. See Sharp v. Caterpillar, Inc., 932 S.W.2d 230, 234 (Tex. App.--Austin 1996, writ requested); Capitan Enters., Inc. v. Jackson, 903 S.W.2d 772, 775 (Tex. App.--El Paso 1994, writ denied).

The common law doctrine of negligence consists of three elements: (1) a legal duty owed by one person to another; (2) a breach of that duty; and (3) damages proximately resulting from the breach. Greater Houston Transp. Co. v. Phillips, 801 S.W.2d 523, 525 (Tex. 1990); El Chico Corp. v. Poole, 732 S.W.2d 306, 311 (Tex. 1987). The threshold issue in a negligence case is whether a duty exists. El Chico Corp., 732 S.W.2d at 311. Whether a duty exists is a question of law for the court to decide from the facts surrounding the occurrence in question. Greater Houston Transp. Co., 801 S.W.2d at 525.

In determining whether the defendant was under a duty, the court will consider several interrelated factors, including the risk, foreseeability, and likelihood of injury weighed against the social utility of the actor's conduct, the magnitude of the burden of guarding against the injury, and the consequences of placing the burden on the defendant. Greater Houston Transp. Co., 801 S.W.2d at 525. The foremost consideration among these factors is the foreseeability of the risk. El Chico Corp., 732 S.W.2d at 311.

Guidry's theory of liability requires a finding of negligence in National's hiring, supervision, or retention of Jaramillo. An employer can be held directly liable for hiring or retaining an incompetent employee, especially where the occupation at issue could cause hazard to others or requires skilled or experienced persons. See Restatement (Second) of Torts § 378 (1965). For example, National has a duty to take steps to prevent injury to the driving public by determining the competency of a job applicant to drive one of its trucks. (2) See 49 C.F.R. § 391.21 (1996). The purpose of this regulatory duty imposed upon long-haul commercial carriers, however, is to promote highway safety and prevent motor vehicle accidents, not to prevent general criminal activity. See 49 C.F.R. § 383.1(a) (1996). Jaramillo's competency to drive a truck is not at issue here.

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State Farm Fire & Casualty Co. v. S.S.
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690 S.W.2d 546 (Texas Supreme Court, 1985)
Capitan Enterprises, Inc. v. Jackson
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Sharp v. Caterpillar, Inc.
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Gulbenkian v. Penn
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Connes v. Molalla Transport System, Inc.
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