Bystander Recovery Is Determined By a Pure Negligence Standard

Discusses the Texas Court of Civil Appeals for Texarkana’s decision in Landreth v. Reed. In Landreth, the court held that bystander recovery in Texas should be determined by a pure negligence standard, rather than relying on standards that require physical impact of zone of danger. The court of civil appeals stated that Texas would adopt the modern view which utilized the traditional concepts of negligence and proximate cause based upon reasonable foreseeability to determine bystander recovery.