In JBS Carriers, Inc v. Washington, et al., the Texas Supreme Court addressed and clarified two important evidentiary issues in the context of a pedestrian-truck collision: (1) the standard for admissibility of evidence concerning mental health and drug or alcohol use and (2) the standard for evaluating negligent training claims.
In JBS Carriers, Mary Turner died following a collision with a JBS Carriers (“JBS”) truck operated by James Lundry. Lundry was making a right turn at an intersection when the truck’s right front fender struck Turner as she was crossing south of the intersection. Turner’s family sued JBS and Lundry, alleging that Lundry was negligent in operating the truck and JBS was negligent for failing to properly train Lundry. During discovery, evidence surfaced that Turner had been diagnosed with and prescribed medicine for paranoid schizophrenia and bipolar disorder. An autopsy also revealed that Turner had drugs and alcohol in her system at the time of the collision, and her medical records noted a history of crack cocaine abuse. At trial, the trial court excluded all evidence of Turner’s mental condition and drug/alcohol use under Rule 403, as well as expert testimony that described Turner’s steady pace as she walked towards the turning truck as something that “fits the scenario of a person[…] having an exacerbation of a severe medical condition.” On appeal, JBS argued the excluded evidence was relevant to Turner’s negligence.
Emphasizing the significance of the difference between prejudicial evidence and unfairly prejudicial evidence under Rule 403, Texas Supreme Court held that the exclusion of this evidence was improper. In this case, the Court determined that evidence of Turner’s mental impairment at the time of the accident was relevant because her judgment and actions immediately prior to the collision were in question. Specifically, the Jury was asked to determine whether Turner’s actions, including walking into the road when she had an unrestricted view of a turning truck, were those of a reasonable person. To the extent any stigma associated with the evidence might have raised prejudice concerns, the Court determined that in this case the evidence would not unfairly invite the jury to decide on an improper basis. Rather, the Court reasoned that the evidence would have presented the jury with a necessary, alternative theory on the key fact issue of why Turner acted the way she did. Moreover, the Court noted that, “the proffered evidence likely would have affected the jury’s allocation or responsibility to both Lundry and Turner, at a minimum.” For this reason, the Court found the erroneous exclusion of the evidence to be harmful error, and reversed and remanded to the trial court for further proceedings.
The Court also addressed a related issue of whether negligent training proximately caused the accident. Turner’s family alleged that the JBS training program fell below the level which a reasonably prudent employer in the industry would have provided as JBS failed to point out a particular blind spot that existed in the front of the truck.
Without confirming whether a cause of action for negligent training even exists, the Court found that there was no evidence in this case that the lack of training was a proximate cause of Turner’s injuries. Specifically, the Court noted that, “there was no evidence that if he had received such training the occurrence would not have happened.” For this reason, the Court reversed the part of the judgment based on the finding that JBS’s direct negligence was a proximate cause of the accident.
The Court’s opinions in JBS Carriers provide valuable guidance for parties in motor vehicle cases on both (1) the admissibility of evidence pertaining to a claimant’s mental health and drug or alcohol usage and (2) the standard governing a negligent training claim, if such a cause of action exists.