A Texas appeals court ruled Wednesday that a jury’s determination regarding two employees at a Mazda dealership is backed by substantial evidence and cannot be overturned by a judge. The decision centers on a car accident that left one employee, Irma Vanessa Villegas, with severe injuries, including paralysis and a traumatic brain injury.
The incident occurred in December 2013 when Christian Ruiz, a co-worker at Rudolph Mazda, struck Villegas with his vehicle after a social gathering following work. This event had involved the consumption of beer, yet both employees tested below the legal limit for alcohol intoxication. Villegas’s injuries ultimately forced her into a nursing home, where she lived until her death in 2020. Following her passing, her daughter, Andrea Juarez, filed a negligence lawsuit against the dealership, Ruiz, and the on-duty manager Marcelo Flores.
In the jury’s findings, Flores was deemed to have acted within the scope of his employment, whereas both Ruiz and Villegas were considered to have been acting outside of their job responsibilities at the time of the accident. The verdict assigned liability for the incident with 25% attributed to Flores, 30% to Villegas, and 35% to Ruiz. Despite concluding that the dealership was not negligent, the jury still allocated 10% of the accident’s responsibility to it. Consequently, the jury awarded Juarez $4 million in damages.
The trial court later granted a new trial to address conflicting findings, notably the inconsistency in the jury’s view that the dealership was not negligent yet was still partially responsible for the incident. However, the Texas Supreme Court intervened by issuing a writ of mandamus, stating that the trial court lacked a sufficient basis for its ruling. The high court instructed the lower court to vacate the order for a new trial and to reconcile the original jury verdict.
Following this ruling, the trial court reversed the jury’s conclusions, asserting as a matter of law that both Villegas and Ruiz were acting within their employment scope at the time of the accident. This prompted the dealership to appeal.
The 8th District Court of Appeals examined the regulations surrounding employers that do not maintain workers’ compensation insurance, noting that such employers are stripped of certain common-law defenses in negligence cases. For instance, they cannot argue contributory negligence from an employee or assert that a co-worker’s negligence was the cause of the injury.
The appellate court found that the jury’s conclusions were justified by evidence indicating that both Villegas and Ruiz remained on the dealership’s property for personal reasons, rather than for work-related purposes. Testimony revealed that the gathering was casual, without formal meeting requirements, and employees were permitted to leave after their shifts ended, with evidence that at least one individual did so.
The court remarked that if employees linger after their workday for personal reasons, they may no longer be within the scope of their employment, even if injuries occur on company premises.
This case underscores the complexities involved in liability and employee conduct in social contexts related to the workplace.
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