Nabors Well Services, Ltd. F/K/A Pool Company Texas, Ltd. and Lauro Bernal Garcia v. Asuncion Romero, Individually and as Representative of the Estate of Aydee Romero, and as Next Friend of Edgar Romero and Saul Romero Esperanza Soto, Individually and as Next Friend of Esperanza Soto, Guadalupe Soto, Maria Elena Soto And Marti
The Texas Supreme Court overruled its 1974 precedent, Carnation Co. v. Wong, which barred evidence of seat-belt nonuse in civil car-accident cases. In this decision, delivered by Justice Brown, the Court held that relevant evidence of a plaintiff's pre-occurrence, injury-causing conduct, such as failure to use a seat belt, is admissible for apportioning responsibility under the state's proportionate-responsibility statute. The Court reasoned that legislative changes to Texas's fault apportionment system and modern seat-belt laws have rendered the old rule anachronistic. The case involved a collision where seat-belt use was disputed, and the trial court had excluded seat-belt evidence based on the Carnation precedent. The judgment of the court of appeals was reversed, and the case remanded for further proceedings consistent with this new interpretation.