United Services Automobile Ass'n v. Keith

In these cross-appeals, the court of appeals described this ease as one in which it “explore[d] the outer boundaries of the bystander cause of action in Texas.” 953 S.W.2d 365. Because the court of appeals exceeded those boundaries when it held that a cause of action may exist under the facts presented here, we reverse the judgment of the court of appeals and render judgment for United States Automobile Association (USAA).

The facts are not in dispute. Dianna Keith’s daughter, Lyndsay Keith, was a passenger in a car that swerved out of control and hit a tree. The owner of the vehicle was…