In FFE Transp. Servs., Inc. v. Fulgham, 154 S.W.3d 84, 89 (Tex. 2004), a trucking company leased a trailer to a long-haul trucker, and while transporting goods, the trailer's upper coupler assembly, which contained a loose or rusty bolt, broke loose, causing the trailer to separate from the tractor and overturn. Fulgham, 154 S.W.3d at 86.
The Court found that expert testimony was required to establish the standard of care since "the upper coupler assembly, kingpin, and base rail of a refrigerated trailer are specialized equipment, and the proper inspection and maintenance of those parts involve techniques unfamiliar to the ordinary person." Id. at 91.
Although the Court recognized that a layman may be able to detect whether a visible bolt is loose or rusty, the Court held that whether that looseness or rust is sufficient to create a danger required specialized knowledge in the tractor-trailer industry. Id.
Thus, an expert was required to testify as to the standard of care. Id.