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Well-Pro Services, L.P. v. Ramon Torres
The Dallas Court of Appeals reversed a $1.84 million judgment against workover rig operator Well-Pro Services after finding legally insufficient evidence that Well-Pro's alleged negligence proximately caused a catastrophic hydrostatic testing accident that impaled Talon Tools employee Ramon Torres. The court held that where Talon's operator prematurely pressurized the testing tool before the next stand of tubing was in place—causing the tool to explosively fail—the evidence conclusively established Talon's conduct as the sole proximate cause, rendering Well-Pro's alleged failures too attenuated under the substantial factor test.