Snellenberger v. Rodriguez
760 S.W.2d 237 · Texas Supreme Court · 1988
Facts
Rodriguez drove her car over a child, critically injuring him. Officer Snellenberger responded to the scene to control the crowd and suffered a fatal heart attack. His widow and children brought a wrongful death action against Rodriguez, relying on the rescue doctrine.
Issue
The legal question is whether Officer Snellenberger's heart attack was a foreseeable result of Rodriguez's negligence, thereby allowing his heirs to recover under the rescue doctrine. The court considered if the rescue doctrine dispenses with the foreseeability requirement for proximate cause.
Holding
The court affirmed the lower court's summary judgment for Rodriguez, holding that Officer Snellenberger's heart attack was not a foreseeable result of Rodriguez's negligence as a matter of law. Therefore, the rescue doctrine did not apply to allow recovery.
Rule
The rescue doctrine does not eliminate the requirement of foreseeability for proximate cause in negligence actions. Foreseeability means an ordinary person should have anticipated the dangers their negligent act created for others.
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