D. Houston, Inc. v. Love, 92 S.W.3d 450 (Tex. 2002), was a case in which an exotic dancer sued her employer for injuries she sustained in a car crash on her way home from work. Love alleged that her employer was responsible for her injuries because her employer encouraged her to accept drinks from patrons of the club. Id. at 454-55. The supreme court agreed, holding that "when an employer exercises some control over its independent contractor's decision to consume alcoholic beverages to the point of intoxication, such that alcohol consumption is required, the employer must make reasonable steps to prevent foreseeable injury to the independent contractor caused by drunk driving." Id. at 457. D. Houston, Inc. v. Love, does not stand for the broad proposition that encouraging one person to do something dangerous (here, drinking to excess) results in a duty by the "encourager" to prevent any injury arising from the dangerous activity. The duty in that case was imposed based on an employer's right, and corresponding duty, to control its independent contractor's behavior.