Snellenberger v. Rodriguez
760 S.W.2d 237 (1988)
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Rule of Law:
Under the rescue doctrine, a negligent actor is not liable for injuries sustained by a rescuer unless the rescuer's injuries were a foreseeable consequence of the negligent act.
Facts:
- Rosita Hernandez Rodriguez drove her automobile and critically injured a small child.
- Harold Snellenberger, a police officer, was notified and proceeded to the scene of the accident.
- Upon arrival, another officer administered CPR to the child.
- Snellenberger's role at the scene was to control the crowd of onlookers, which included the child's mother.
- While controlling the crowd, Snellenberger suddenly collapsed.
- Snellenberger later died of a heart attack.
Procedural Posture:
- The heirs of Harold Snellenberger brought a wrongful death action against Rosita Hernandez Rodriguez in a Texas trial court.
- The trial court granted summary judgment in favor of the defendant, Rodriguez.
- The plaintiffs (appellants) appealed to the Texas court of appeals.
- The court of appeals affirmed the trial court's judgment in favor of Rodriguez (appellee).
- The plaintiffs (petitioners) then appealed to the Supreme Court of Texas.
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Issue:
Does the rescue doctrine impose liability on a negligent actor for a rescuer's fatal heart attack that occurs while the rescuer is performing crowd control at an accident scene, where such an injury is not a foreseeable consequence of the initial negligent act?
Opinions:
Majority - Gonzalez, J.
No. A negligent actor is not liable for a rescuer's injury if that injury was not a foreseeable result of the negligence. The rescue doctrine does not eliminate the fundamental requirement of foreseeability in negligence actions. Proximate cause consists of two elements: cause in fact and foreseeability. Foreseeability means that an actor of ordinary intelligence should have anticipated the dangers their negligent act created for others. In this case, as a matter of law, it was not foreseeable that a driver's negligence in causing an accident would result in a police officer suffering a fatal heart attack while performing crowd control at the scene. The court can decide this issue as a matter of law without it going to a jury.
Dissenting - Robertson, J.
Yes. The majority misapplies the rescue doctrine by focusing on the foreseeability of the specific injury rather than the foreseeability of the rescuer's intervention. The core principle of the rescue doctrine is that a rescuer's intervention and resulting injury are deemed foreseeable as a matter of law once a defendant negligently creates a perilous situation. Therefore, whether Rodriguez could have specifically foreseen a heart attack is not the correct legal question. The dissent also argues that summary judgment was improper because a genuine issue of material fact existed as to whether the child was in imminent peril, a key element for applying the rescue doctrine, which should have been decided by a jury.
Analysis:
This decision significantly clarifies the scope of the rescue doctrine in Texas by affirming that it does not operate as an exception to the fundamental negligence element of foreseeability. The court establishes that the specific harm suffered by the rescuer must be a foreseeable consequence of the defendant's negligence, not just the rescuer's presence at the scene. By holding that foreseeability can be determined as a matter of law in this context, the ruling may limit the ability of rescuers to recover for indirect or unusual injuries, such as those caused by emotional stress, and empowers courts to dismiss such claims before they reach a jury.
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