Travis v. City of Mesquite

In Travis v. City of Mesquite, 830 S.W.2d 94 (Tex. 1992), two off-duty police officers were working at a truck stop as late-night security guards. Id. at 96. Suspicious that the occupants of a car in the back parking lot were involved in prostitution, the officers obtained the driver's identification and asked him to drive to the front parking lot and wait for them there. Id. Instead, the driver fled the scene, and the off-duty police officers followed him as he drove the wrong way down a one-way highway access road. Id. The fleeing driver then crashed head-on into another motorist's car, killing one person and injuring others. Id. The victims of the crash sued the city and the police officers for negligence, among other liability theories. Id. at 96-97. The defendants sought summary judgment on several theories including the absence of proximate cause, and the trial court granted summary judgment for the defendants. Id. at 97. The court of appeals affirmed based on the absence of proximate cause, but the supreme court reversed based on the following causation analysis: "The . . . summary judgment evidence raises the inference that the fleeing motorist drove down the access road at excessive speed because of the police decision to give chase. There was summary judgment evidence that the conduct of the police officers was a cause in fact of the accident in question, and of the injuries for which the plaintiffs seek recovery." Id. at 98.