Article 2212a, Section 2(e), Abrogates the One Satisfaction Rule in Comparative Negligence Actions

Examines the Texas Supreme Court’s decision in Cypress Creek Util. Serve. Co. v. Muller. In Cypress, the Court held that the Comparative Negligence Statute—article 2212(a), section 2(e)—abrogated the “one satisfaction rule” from Bradshaw v. Baylor University. The author warns that prospective plaintiffs have a duty to “balance the factors attributable to each subsection before deciding which type of contribution to pursue.”