Nabors Drilling, U.S.A., Inc. v. Escoto
The Texas Supreme Court reversed a court of appeals' decision, reinstating a trial court's take-nothing judgment in a negligence case. The case involved the families of accident victims (collectively, Escoto) suing Nabors Drilling U.S.A., Inc. after an off-duty, fatigued employee, Robert Ambriz, caused a fatal car accident after a 12-hour night shift. The plaintiffs argued Nabors was negligent by creating work conditions that induced extreme fatigue and by failing to train employees about its dangers. The Supreme Court held that an employer has no duty to prevent injuries caused by off-duty, fatigued employees, nor a duty to train them about fatigue. The Court distinguished fatigue from intoxication cases, noting the lack of a quantitative measure for fatigue, the difficulty for employers to control off-duty factors, and the common knowledge of driving while fatigued being a risk. The Court emphasized that an employer must affirmatively exercise control over an incapacitated employee due to known impairment for such a duty to arise, which was not the case here.