Canas v. Centerpoint Energy Resources Corp.
Justice Christopher partially concurs and partially dissents from Chief Justice Frost's and Justice Jamison's opinions regarding CenterPoint's liability limitations under its tariff. She agrees that the tariff limits liability for negligence and strict liability but disagrees with aspects of Frost's analysis. Christopher concurs with remanding the intentional misrepresentation claim but believes negligent misrepresentation should be affirmed. She disagrees with Frost's disposition of the gross-negligence claim, arguing the entire issue should be remanded, emphasizing that tariff limitations for gross negligence and willful misconduct are against public policy and unenforceable. Christopher agrees that negligence per se claims don't survive tariff limitations but challenges Frost's reasoning, asserting that the tariff must yield to conflicting federal or state statutes or regulations. However, she ultimately finds no actual conflict between the tariff's liability limitation and the cited regulations, concluding that the elimination of liability for negligence per se is valid.