Here's an analysis of the case Gonzalez v. Sanchez decided by the Texas Court of Appeals (Eastland) in June 2025. You can read the full opinion by clicking here.

This case involves a motor vehicle accident between Tiffany Gonzalez (plaintiff/appellant) and Eladio Caballero Sanchez, a commercial truck driver for E&G Sanchez Trucking (defendant/appellee). Gonzalez sued Sanchez and his company for personal injuries from the collision. A jury found both parties negligent but assigned 60% responsibility to Gonzalez and 40% to Sanchez. The trial court entered a judgment in favor of Sanchez based on this.

Key Facts

  • The accident happened at an intersection where Sanchez stopped at a stop sign on FM 846 and started crossing US Highway 87.
  • Gonzalez was driving south on US 87 at about 75 mph and collided with the truck.
  • Gonzalez admitted to sending/receiving over 30 text messages while driving shortly before the accident, though she claimed her vehicle's Bluetooth read the texts aloud and she responded by voice.
  • Gonzalez swerved left to avoid the truck but still hit it.
  • The truck partially obstructed the southbound turn lane but not through lanes.
  • Gonzalez’s statements about when she first saw the truck and her speed before impact were inconsistent.
  • The investigating trooper did not find evidence Gonzalez braked before impact.
  • Gonzalez's cell phone records and 911 call records were admitted despite her objections.
  1. Whether the evidence was legally and factually sufficient to support the jury’s negligence findings assigning 60% responsibility to Gonzalez.
  2. Whether the trial court abused its discretion by admitting Gonzalez’s cell phone records.

Court’s Reasoning and Holdings

  • The court emphasized Texas’s comparative negligence (proportionate responsibility) framework, which allows a plaintiff to recover damages reduced by their percentage of fault, even if they have some fault.
  • To assign negligence to Gonzalez, the evidence had to show she failed to keep a proper lookout or otherwise was negligent, and that her negligence was a proximate cause of the accident.
  • Gonzalez’s admitted texting while driving, even if by voice command, was relevant and admissible evidence that could show distraction and failure to maintain proper lookout.
  • The court found sufficient evidence that Gonzalez's cell phone activity could have contributed to the accident, and that her inconsistent statements about her awareness of the truck and timing supported the jury's findings.
  • The court distinguished this case from others where evidence was insufficient because here there was a full trial record with conflicting evidence for the jury to weigh.
  • The trial court did not abuse discretion admitting the cell phone records because they were relevant to the issue of negligence and causation.
  • The jury’s responsibility apportionment was supported by legally and factually sufficient evidence.

Outcome

The Court of Appeals affirmed the trial court’s judgment, upholding the jury’s negligence findings against Gonzalez and the admission of her cell phone records.

Summary Takeaway

This case underscores how Texas courts will consider evidence of distracted driving, including cell phone use, as relevant to negligence and fault in motor vehicle accidents. Even indirect or voice-command texting can support a finding of negligence if it may have contributed to failing to keep a proper lookout. Conflicting testimony and inconsistent statements about awareness and timing are for the jury to weigh. The admission of cell phone records is within the trial court’s discretion if relevant to causation. Comparative negligence allows fault to be split and damages adjusted accordingly, rather than barring recovery entirely.

The Girards Law Firm specializes in severe injury and wrongful death cases, especially those that involve birth injuries, brain damage, heart damage, spinal cord injuries, severe burns, commercial plane crashes and commercial trucking crashes nationwide, and especially in Texas, Arkansas and Oklahoma. James E. Girards is a private pilot licensed to fly single- and multi-engine aircraft in both visual and instrument conditions. Contact us at www.girardslaw.com by using the chat feature for more information.

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