Union Pump Co. v. Allbritton
Justice Cornyn's concurring opinion in 'Allbritton's Claim' highlights the historical development of causation in American and Texas jurisprudence, criticizing the Court's opinion for conflating foreseeability and cause-in-fact. He advocates for a bifurcated causal analysis, distinguishing between cause-in-fact (using 'but for' and 'substantial factor' tests as factual inquiries) and legal/proximate cause (incorporating foreseeability and policy-based limitations on liability). Applying this framework to Sue Allbritton's injury, Justice Cornyn argues that while the defective pump was a cause-in-fact, neither Union Pump's negligence nor the defective pump was a legal cause or producing cause of her injury. This is because her injury was not foreseeable and did not occur in a natural and continuous sequence from the defect, but rather resulted from a dangerous shortcut taken after the crisis had subsided, placing her outside the scope of products liability protection. Consequently, he concurs in the Court's judgment, which effectively denies Allbritton's claim, but for the distinct reasons outlined in his analysis.