R & R Contractors and R & R Field Services, Inc. v. Mary Torres
This case involves an appeal from the Thirteenth District of Texas, Corpus Christi, regarding a wrongful death action. Gregorio Torres, Jr., an employee of R&R Contractors and R&R Oilfield Services, Inc., died after a thousand-pound tank fell on him during unloading operations. His surviving spouse and children filed a gross negligence suit under the Texas Workers' Compensation Act, and a jury awarded $200,000 in punitive damages. On appeal, R&R raised two issues: the legal sufficiency of the evidence for gross negligence and the trial court's refusal to apply a 'clear and convincing evidence' standard for exemplary damages. The appellate court agreed that the trial court erred by using a 'preponderance of the evidence' standard, citing changes from the 1995 tort reform legislation. However, the court found the evidence legally sufficient to support the jury's finding of gross negligence against both the employee-operator and the corporation, based on extreme risk and conscious indifference to safety. The judgment of the trial court was reversed and remanded for further proceedings due to the incorrect standard of proof.