Bed, Bath & Beyond, Inc. v. Rafael Urista

Summary

The Texas Supreme Court considered whether submitting unsupported inferential rebuttal instructions on unavoidable accident and new and independent cause constituted harmful charge error in a premises-liability case involving merchandise falling from a store shelf. The Court held that the error was harmless and affirmed the judgment, while Justice Medina, joined by Chief Justice Jefferson, dissented. The dissent argued that the instruction likely influenced the jury’s finding that Bed, Bath & Beyond was not negligent and that a new trial was warranted.

Holdings

1. An unavoidable-accident instruction is proper only when the evidence raises a question whether the event was proximately caused by a condition or circumstance beyond the control of the parties, rather than by negligence of a party.
2. The dissent would hold that the unsupported unavoidable-accident instruction was harmful because it confused the jury and probably caused the negative answer to the only liability question the jury reached.
3. The dissent agreed that Casteel did not apply because the charge contained a single negligence theory rather than a broad-form liability question commingling valid and invalid theories.

Questions Presented

1. Whether the trial court improperly submitted unavoidable-accident and new-and-independent-cause inferential rebuttal instructions without evidentiary support.
2. Whether the erroneous unavoidable-accident instruction probably caused the rendition of an improper judgment and therefore required a new trial.
3. Whether the broad-form submission rule of Crown Life Insurance Co. v. Casteel applied to the charge error.

Disposition

other