A Texas court of appeals recently approved of a jury verdict dismissing the plaintiffs’ claims in a car accident case that suddenly turned into a wrongful death action after the lead plaintiff committed suicide.
The case, captioned Huffines v. Buxton, stemmed from a 2011 accident at a Houston intersection that occurred when Barbara Buxton drove her car through a divided thoroughfare and was broadsided by David Huffines. No air bags deployed in the wreck and neither required immediate medical attention.
Huffines began to experience pain and discomfort shortly after the accident and felt pain in his neck, back and groin — all locations where he had pre-existing conditions. He underwent several medical procedures to alleviate the pain. But the pain intensified and Huffines told friends and family he was contemplating suicide. During the pendency of his car wreck case, Huffines took his own life.
Huffine’s wife and daughter later turned the car wreck case David filed in a Harris County district court into a wrongful death action.
David Huffines’ deposition testimony was read into evidence that when the accident occurred a Thermos cup he was holding pressed into his abdomen and groin, causing the injuries.
At trial, defense attorneys elicited testimony about David’s pre-existing conditions from his surviving family members including that he had hernia surgery seven years before the accident. The family members also testified that David suffered severe neck and back injuries from another collision 11 years earlier in which he was hit head-on by a wrong-way driver who was intentionally trying to kill herself.
A jury ultimately determined that Buxton’s negligence did not cause David’s injuries at the time of his death nor proximately caused his death, prompting the trial court to sign a take-nothing judgment for the defense.
The Huffines family later appealed the judgment to Houston’s Fourteenth Court of Appeals arguing among other things that the evidence was legally factually insufficient to support the jury’s finding that Buxton was not liable for David’s injuries and death.
In her opinion, Justice Tracy Christopher concluded that the plaintiffs’ legal sufficiency challenge failed because the record of the case contained evidence from which the jury could have reasonably concluded that David’s injuries and death were not caused by Buxton’s negligence.
“The jury heard testimony that the accident with Barbara [Buxton] was relatively minor: no air bags deployed; no one complained of injuries at the scene of the accident; and both parties drove away without the assistance of the police, emergency medical personnel, or a tow truck driver,” Christopher wrote.
“The jury also heard testimony that David had suffered serious injuries in his past, which could have been responsible for the pain he claimed after the accident with Barbara,” Christopher added. “Crediting this evidence as we must, we conclude that there is legally sufficient evidence to support the jury’s implied finding that Barbara’s negligence did not proximately cause David’s injuries.”