Debra Smith v. James East, Individually and D/B/A Avery Fine Wines & Spirits And Terri Bayless East, Individually and D/B/A Avery Fine Wines & Spirits
Debra Smith appealed a take-nothing judgment in a wrongful-death action following her daughter S.S.'s death from alcohol poisoning. Smith sued James East and Terri Bayless East, owners of Avery Fine Wine & Spirits, for allegedly providing alcohol to S.S., a minor, alleging common-law negligence and negligence per se. A jury found James 35% responsible, S.S. 25% responsible, and Smith 40% responsible. The district court denied recovery, applying Texas's proportionate responsibility scheme which treats a wrongful-death plaintiff and the decedent as a single 'claimant' whose combined responsibility (65%) exceeded the 50% recovery threshold. The appellate court affirmed, holding that binding precedent compelled the conclusion that Smith and S.S. are a single 'claimant' for purposes of section 33.001, thus barring recovery.