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Jose Navarrete v. Rey & K Services, Reynol Gaytan and Karina Gaytan D/B/A Rey & K Services

2026-08-25

Summary

Holding. The court affirmed the trial court's grant of summary judgment in favor of Rey & K Services, finding that Navarrete failed to present more than a scintilla of evidence establishing a breach of duty and proximate causation for his negligence claim based on inadequate training.

Jose Navarrete, an employee of an oilfield services company, suffered severe injuries when a wellhead fell on him during a well-plugging operation. He sued Rey & K Services, which had provided periodic safety training to his employer's workforce over several years, including lockout/tagout and fall-protection sessions. Navarrete claimed Rey & K negligently failed to provide adequate training, which he argued caused the accident.

The trial court granted Rey & K's motion for no-evidence summary judgment, and Navarrete appealed. The appellate court affirmed, finding that while Navarrete presented evidence that Rey & K had provided some training, he failed to present more than minimal evidence showing what specific training deficiencies existed, whether he actually failed to follow the training provided on the day of the incident, or whether better training would have prevented his injuries. The court noted that merely proving training occurred was insufficient to support a negligence claim without evidence of inadequate training and a causal connection to the accident.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether no-evidence summary judgment was properly granted when plaintiff presented evidence of training but not of inadequate training or causation
  • Whether evidence that training occurred is sufficient to support a negligence claim for inadequate training
  • Whether a company's post-incident report acknowledging failure to follow procedures constitutes evidence of inadequate prior training

Procedural posture

Navarrete appealed from the trial court's grant of summary judgment on his negligence claim against Rey & K Services, a safety training provider to his employer.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

In The

Court of Appeals

Seventh District of Texas at Amarillo

No. 07-26-00175--CV

JOSE NAVARRETE, APPELLANT

V.

REY & K SERVICES, REYNOL GAYTAN AND KARINA GAYTAN D/B/A REY & K

SERVICES, APPELLEES

On Appeal from the 84th District Court

Ochiltree County, Texas

Trial Court No. CV15395, Honorable Curtis W. Brancheau, Presiding

August 25, 2026

MEMORANDUM OPINION

Before DOSS and YARBROUGH and PRATT, JJ.

This appeal arises from an incident which occurred during the plugging of an oil

well. Appellant, Jose Navarrete, challenges the granting of summary judgment in favor

of the Appellees, Rey & K Services, Reynol Gaytan and Karina Gaytan, d/b/a “Rey & K

Services” (collectively “Rey & K”). Navarrete contends the trial court should not have

granted summary judgment because: (1) genuine issues of material fact existed

precluding the granting of a traditional summary judgment; (2) he presented sufficient

evidence to preclude the granting of a no-evidence summary judgment; (3) the trial court resolved disputed fact issues by relying on extra-record knowledge; and (4) the trial court

should not have struck his attached evidence which demonstrated the existence of

genuine issues of material fact. We affirm.

BACKGROUND

On October 18, 2022, Jose Navarrete, an employee of Phil Dollar Oilfield Services,

Inc. (PDOS), was assisting a well-plugging crew with the removal of a wellhead.

Navarrete and his coworkers unearthed the wellhead using a backhoe and some shovels.

The wellhead needed to be separated from the casing of the well before the plugging

process could be completed. To cut the casing, Navarrete and his coworkers raised the

wellhead by rigging it to a chain wrapped around the teeth of the backhoe. Navarrete

operated the backhoe and created tension in the chain, suspending the wellhead while

his coworkers cut the inner and outer casing. At some point, Navarrete left the backhoe

running unattended and climbed into the pit to help with the final cut. Unfortunately, during

this process, the backhoe shifted; the chain came loose; and the wellhead fell, striking

Navarrete and pinning him to the side of the excavation. The injury left Navarrete

paralyzed from the waist down.

Since 2018, Rey & K had provided periodic safety training to PDOS’s workforce.

These training sessions included SafeLand training, H2S certification, first aid/CPR, and

topic-specific classroom sessions (protective gear, lockout/tagout, safe driving,

hazardous chemicals, hand/power tools). Specifically, in the two months prior to the

incident, Rey & K conducted a lockout/tagout session and a fall-protection session. After

the incident, PDOS hired Rey & K to assess the incident and determine its causes. Rey

& K’s report cited the backhoe being left “ON” and unattended, attributing the unsafe

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conditions to “NOT FOLLOWING BASIC STEPS/PROCEDURES” and the cause of the

unsafe acts to “MACHINERY UNATTENDED (BACKHOE), HUMAN ERROR.”

Following the incident, Navarrete sued the owner of the well, the operator of the

well, and Rey & K under theories of negligence and premises liability. Navarrete also

sought damages for gross negligence. Rey & K moved for both a no-evidence summary

judgment and a traditional summary judgment on Navarrete’s claims. Navarrete

responded with evidence of Rey & K having provided training to PDOS employees.

Navarrete did not contest the premises-liability claim and waived his gross-negligence

claims, leaving negligence as the only claim at issue. He argued Rey & K breached its

duty to provide sufficient training which proximately caused Navarrete’s injuries.

The trial court held a hearing on Rey & K’s motions for summary judgment on

March 15, 2026. At the hearing, Rey & K urged the trial court to strike Navarrete’s

affidavit, his interrogatory responses, and certain evidence referenced in, but not attached

to, Navarrete’s response. The trial court overruled the objection to the affidavit, but he

granted the other evidentiary objections. After hearing the arguments of counsel, the trial

court granted summary judgment and granted Rey & K’s motion for severance, making

the summary judgment final and appealable. Navarrete timely filed his notice of appeal.

ANALYSIS

By his four issues, Navarrete argues summary judgment should not have been

granted by the trial court. We review an order granting summary judgment de novo, taking

as true all evidence favorable to the nonmovant and indulging every reasonable inference

in the nonmovant’s favor. JLB Builders, L.L.C v. Hernandez, 622 S.W.3d 860, 864 (Tex.

2021) (citations omitted). To be entitled to traditional summary judgment, the movant has

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the burden to prove that no genuine issue of material fact exists and that the movant is

entitled to judgment as a matter of law. Id. By contrast, a party may obtain a no-evidence

summary judgment when there is no evidence of one or more essential elements of a

claim or defense on which an adverse party would have the burden of proof at trial. Id.

A properly filed no-evidence motion shifts the burden to the nonmovant to present

evidence raising a genuine issue of material fact supporting each element contested in

the motion. Id. “[A] no-evidence summary judgment is improperly granted if the

respondent brings forth more than a scintilla of probative evidence to raise a genuine

issue of material fact.” Id. (quoting King Ranch, Inc. v. Chapman, 118 S.W.3d 742, 751

(Tex. 2003). Where, as here, a trial court does not specify the grounds on which it granted

the motion for summary judgment, we must affirm if any of the grounds asserted in the

motion are meritorious. Cmty. Health Sys. Prof’l Servs. Corp. v. Hansen, 525 S.W.3d

671, 680 (Tex. 2017). Further, when the motion asserts both no-evidence and traditional

grounds, we review the no-evidence grounds first, Navarrete’s second issue.1 Id.

Rey & K’s no-evidence motion for summary judgment averred Navarrete lacked

evidence for the elements of his claims for negligence, premises liability, and gross

negligence. Because Navarrete failed to respond by pointing out evidence supporting

each element of his claim for premises liability and gross negligence, a no-evidence

summary judgment dismissing those claims against Rey & K was proper. TEX. R. CIV. P.

166a(i) (West 2025, amended 2026); TEX. R. APP. P. 33.1. Therefore, we only address

Navarrete’s challenge to the summary judgment in favor of Rey & K on his claim of

1 By his second issue, Navarrete claims the trial court erred in granting a no-evidence summary

judgment because he produced more than a scintilla of probative evidence on each challenged element of his negligence claim.

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negligence. Wilson v. Nw. Tex. Healthcare Sys., Inc., 576 S.W.3d 844, 848 (Tex. App.—

Amarillo 2019, no pet.) (“We will affirm a no-evidence summary judgment if the record

shows . . . there is no evidence on the challenged element[.]”).

The elements of a negligence cause of action are: (1) the existence of a legal duty,

(2) a breach of that duty, and (3) damages proximately caused by the breach. Tenaris

Bay City Inc. v. Ellisor, 718 S.W.3d 193, 197 (Tex. 2025). Proximate cause has two

elements: (1) cause in fact, and (2) foreseeability. Id. Cause in fact, in turn, also has two

essential components: (1) “but for” causation, and (2) “substantial factor” causation. Id.

(quotations orig.). The plaintiff must establish both elements of cause in fact in order to

prevail on a negligence claim. Id.

Rey & K moved for a no-evidence summary judgment on Navarrete’s negligence

claim arguing there is no evidence of a duty owed to Navarrette, no evidence of a breach

of any duty, and no evidence any such breach proximately caused Navarrete’s injuries.2

Attached to his response, Navarrete presented his affidavit; copies of his answers to

interrogatories from Rey & K; Rey & K’s incident report; transcript of the deposition of Lori

Dollar, Vice President and Secretary of PDOS; safety records from PDOS, including

certificates of training issued by Rey & K to Navarrete; transcript of the deposition of

Reynol Gaytan; and an OSHA lockout/tagout fact sheet.3 In the body of his response,

Navarrete also cited evidence Rey & K provided “lockout/tagout” training of some sort.

2 While Navarrete’s petition raised a general claim of negligence against all the defendants and

listed a variety of acts he attributed to all defendants, he conceded in his response that “Mr. Navarrete sued . . . [Rey & K] for negligence in its [sic] training of PDOS employees, including himself.”

3 The trial court excluded Navarrete’s interrogatory responses from the evidence pursuant to Rey

& K’s motion to strike. It appears from the pleadings, however, Navarrete only pointed to his interrogatory response as evidence he suffered paralysis from the incident. However, because our disposition does not turn on evidence of damages but rather evidence of causation, we do not address the exclusion.

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Navarrete contends this is more than a scintilla of evidence demonstrating Rey & K, by

providing training, owed him a duty to train him adequately, and by not training him

adequately Rey & K breached that duty and caused the incident. Assuming, arguendo,

Navarrete presented sufficient evidence of a duty owed by Rey & K, he still failed to

present more than a scintilla of evidence demonstrating Rey & K breached that duty and

Rey & K’s breach proximately caused his injuries.4

Navarrete points to his affidavit as evidence demonstrating breach of duty and

proximate causation. The affidavit only makes the following relevant statements:

• “I left the backhoe unattended and turned on so that I could help other

workers plugging the well.”

• “When I left the backhoe unattended and turned on, I was acting

consistently with the training that I received while working at Phil Dollar

Oilfield Services.”

However, neither of these statements tie Navarrete’s actions to any specific training he

received (or did not receive) from Rey & K. Nor do they articulate any appropriate

standard of care in training of this kind or causation of the incident. He also points to the

deposition of Reynol Gaytan—a principal of Rey & K Services—for the proposition Rey &

K breached their duty by inadequately training him. However, Gaytan only confirmed the

use of the backhoe by Navarrete was not “consistent with proper training.” Gaytan’s

testimony does not indicate Rey & K gave him inadequate training. Neither does it

4 At the moment, the Texas Supreme Court has yet to recognize a cause of action for negligent

training, and whether a corresponding duty exists is still an open question. See Pagayon v. Exxon Mobil Corp., 536 S.W.3d 499, 505 (Tex. 2017). However, we need not address whether Rey & K owed a duty as a matter of law because, as described infra, Navarrete failed to provide more than a scintilla of the remaining elements of his negligence claim.

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elucidate any training details, or whether, but for Navarrete following that training, the

incident would not have occurred.

Lastly, Navarrete insists the evidence is more than a scintilla, arguing that Rey &

K’s training was deficient because Rey & K’s accident report stated a cause of the

accident was “NOT FOLLOWING BASIC STEPS/PROCEDURES.” He argues this is an

“admission” by Rey & K that they inadequately trained Navarrete which caused the

accident. But, again, there is no evidence of what procedures or basic steps were taught

to Navarrete, whether he actually followed the procedures on the day of the accident, and

whether, but for following the procedures, Navarrete would not have suffered his injuries.

Simply put, presenting evidence that Rey & K trained Navarrete is not enough.

Navarrete failed to produce more than a scintilla of evidence for the essential elements

of breach of duty and proximate causation for his negligence claim. Therefore, the trial

court did not err in granting Rey & K’s motion for a no-evidence summary judgment on

Navarrete’s claims. We overrule Navarrete’s second issue.

CONCLUSION

Because the no-evidence summary judgment was properly granted, we need not

address his remaining issues. TEX. R. APP. P. 47.1. The judgment of the trial court is

affirmed.

Laura A. W. Pratt

Justice

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