## Facts

- Renee McCracken Williams was driving on a four-lane portion of Interstate 35 in Austin, Texas, with her two minor children as passengers.
- Her vehicle ran out of gasoline, stalled in a center lane, briefly restarted, and stalled again; testimony indicated the vehicle was difficult for approaching drivers to see due to an overpass shadow.
- Robert Robinson, an employee of Steves Industries, Inc., was driving Steves’s eight-ton equipment repair truck and rear-ended Williams’s stalled vehicle.
- Williams suffered personal injuries; both children died from injuries sustained in the collision.
- The Williamses sued Steves Industries for actual damages and punitive damages, alleging negligent entrustment and asserting that Steves was negligent and grossly negligent in allowing Robinson to operate the truck.
- A jury found Steves negligent and grossly negligent and awarded $250,000 in punitive damages, but the trial court disregarded the gross-negligence finding and limited recovery to actual damages.
- The court of appeals largely affirmed, and the Supreme Court of Texas granted review.

## Issues

1. Whether legally sufficient evidence supported a finding that Steves Industries was grossly negligent in entrusting its truck to Robinson, allowing punitive damages on a negligent-entrustment theory.
2. Whether Williams’s conduct in running out of gasoline and stalling on the interstate was a proximate cause of the collision supporting comparative fault.

## Decision

- The Supreme Court of Texas affirmed the court of appeals’ judgment.
- The Court held there was no evidence that Steves acted with gross negligence in entrusting the truck to Robinson; punitive damages were therefore unavailable.
- The Court held there was sufficient evidence that Williams’s failure to maintain sufficient gasoline, resulting in a stall in an interstate lane, was a proximate cause of the collision and could be considered in allocating fault.

## Legal Principles

- Negligent entrustment requires: (1) entrustment of a vehicle, (2) to an unlicensed, incompetent, or reckless driver, (3) with the owner’s actual or constructive knowledge of that condition, (4) driver negligence on the occasion, and (5) proximate causation of the accident.
- Punitive damages for negligent entrustment require proof that the entrustor was grossly negligent in making the entrustment.
- Gross negligence requires more than ordinary negligence; it demands proof of an extreme degree of risk and the actor’s conscious indifference to others’ rights or safety.
- Lack of a required license may support ordinary negligence, but without evidence that the entrustor knew of dangerous driving tendencies or similar facts showing conscious indifference, it does not establish gross negligence.
- Proximate cause requires cause in fact and foreseeability; creating a hazardous condition by stalling in a high-speed traffic lane can satisfy both elements.

## Conclusion

The Texas Supreme Court held that entrusting a heavy truck to an unlicensed employee, without evidence of known dangerous driving tendencies or conscious indifference, did not support gross negligence or punitive damages, and it upheld comparative fault because the plaintiff’s out-of-gas stall in an interstate lane was a foreseeable cause in fact of the rear-end collision.


Williams v. Steves Indus., Inc., 699 S.W.2d 570 (Tex. 1985)