Snellenberger v. Rodriguez

760 S.W.2d 237 · Texas Supreme Court · 1988

Facts

Rodriguez negligently struck a child with her car. Officer Snellenberger responded to the accident scene to manage the crowd, where he suffered a fatal heart attack. His heirs sued Rodriguez, invoking the rescue doctrine.

Issue

Did Officer Snellenberger's fatal heart attack, suffered while responding to an accident caused by the defendant's negligence, constitute a foreseeable injury under the rescue doctrine?

Holding

The court affirmed the lower court's decision, holding that the officer's heart attack was not a foreseeable result of the defendant's negligence, thus precluding recovery.

Rule

Proximate cause in negligence actions requires both cause in fact and foreseeability, meaning an actor must have anticipated the dangers of their negligent act. The rescue doctrine does not dispense with this foreseeability requirement.

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.