Texas Parking Lot Injury Claims: Evidence to Trial Guide

A Texas parking lot injury claim starts with what actually happened, who controlled the car or the spot where you were hurt, and what evidence still exists. Drivers, property owners, contractors and government bodies are judged under different rules. Several can share fault, but each one needs its own proof of duty, breach, causation and damages, and some deadlines arrive long before the general two-year limit.

If you were hurt by	The claim usually turns on	Where to read more
A car backing out of a space	The driver's lookout, speed and chance to stop	Section 6 below.
A pothole, exposed anchor or broken wheel stop	Who controlled the spot, whether it was unreasonably dangerous, and what they knew	Sections 7 to 10.
Water, oil or ice	How long that specific condition was there	Sections 10 and 15.
A fall near active paving work	The contractor's work and who controlled the route	Section 12.
A city, county, school or state lot	Immunity, the Tort Claims Act and a six-month notice deadline	Sections 4 and 20.

The examples in this guide are hypothetical. They are teaching tools, not accounts of any client, case or result.

Before you go further	Details
Talk to a lawyer about your facts	Request a case review or call (214) 200-4878. Have the lot location, date, injury and any photos ready.
Who handles these cases at the firm	Aaron Herbert is Board Certified in Personal Injury Trial Law by the Texas Board of Legal Specialization. His State Bar of Texas profile shows a Texas license dated November 6, 2002 [S1].
The firm's parking lot practice page	Texas parking lot injury lawyer.

1. What exactly happened in the parking lot?

Start with the physical sequence, because "parking lot accident" can describe three very different cases.

Hypothetical event	First question	Likely theory
A reversing SUV strikes a shopper walking to the store	What could the driver see, and when did the shopper enter the lane?	Driver negligence.
A driver swerves around an unmarked excavation and hits another car	Who dug it, and who should have marked or closed it?	Contractor or premises claim, plus the other driver.
A customer trips on a wheel-stop anchor with no car moving nearby	Was the anchor in the walking route, and who maintained it?	Premises claim.

Separate the first cause from things the impact knocked loose. A broken wheel stop photographed afterward may have broken before the fall or during it.

Build the timeline from	Watch for
Your account and witness accounts	Mark what you saw yourself versus what someone told you later.
Receipts, parking-app records and emergency calls	Clocks on different devices often disagree, so note estimates instead of forcing an exact minute.
Photos and recordings	A competing explanation stays open until the evidence rules it out.
The final event statement	It should fit in a few sentences: place, person, movement or condition, contact or fall, injury.

Picking a property-defect theory before looking at the driver can leave the strongest claim undeveloped. Picking only the driver theory can miss a condition that also contributed.

Who	What helps most now
The injured person	An honest description, including "I didn't see that."
Counsel	Keeping both driver and property theories open until the proof narrows them.

2. Why should medical care come before photos?

A parking lot is still live traffic after an injury, so get out of danger and get care before anyone documents the scene.

Do	Don't
Call for emergency help when the injury or the scene calls for it	Stand behind cars or in a drive lane to take a picture.
Let a companion collect names and plates while you're treated	Try to measure a pothole while injured.
Tell the clinician how it happened and which body parts were hit	Leave out a head strike, a blackout or new weakness.
Mention earlier injuries to the same area	Hide prior history; it hurts both care and credibility.

A prior injury doesn't automatically defeat a claim for a new injury or an aggravation. Concealing it can.

Keep	Why
Discharge papers, referrals, prescriptions and restrictions	They show what care was recommended and when.
A note of real barriers to follow-up (rides, scheduling, money)	A gap explained at the time is more credible than one explained after an insurer raises it.
A simple folder of visit dates and questions for providers	It supports accurate recall without becoming a symptom script.
Notes on good days as well as bad ones	The claim is about actual harm, not making every day sound equally severe.

Counsel compares the mechanism with the chart. A billing code or an MRI finding may not show that this event caused the condition, so some questions need a qualified medical opinion that accounts for earlier symptoms and later events.

Medical question	Usually answered by
Did the fall or impact cause this diagnosis?	A treating or retained physician who knows the full history.
Is this a new injury or an aggravation?	Records from before and after the event, compared by a qualified doctor.

3. Who should you report a parking lot injury to?

Report a crash to police and the other driver's insurer, and report a fall or property hazard to the manager or operator, keeping the reference number and the name of the person you told.

Event	Report to	Get
Vehicle collision	Police as appropriate; exchange driver, vehicle, employer and insurance details	The incident or case number.
Fall or property hazard	The store manager, property manager or lot operator	An incident reference and the recipient's name.
Both (for example, a car hit you while you detoured around a hazard)	Both paths	Both references.

Say what you saw, not what you assume. If you only noticed the water after you fell, the report should say that.

On the report form	Hypothetical example
Something you saw	"Clear liquid near the cart corral by row F."
Something a witness told you	"A man in a red cap said he told an employee about it earlier."
Something to avoid signing without reading	A release or a broad medical authorization.
A precise location	Row and aisle, nearest light pole, parking-ticket number or a map pin.

A shopping center can have several addresses, shared parking and different management zones. A photo of the nearest storefront doesn't prove who controlled the aisle.

Record type	Who usually holds it
The crash report	TxDOT keeps crash records [S4].
Scene photos, bodycam video and field notes	The investigating police agency.
How the crash is coded	TxDOT's CR-100 instructions have a separate box for crashes that start and end in a parking lot or on private property, and TxDOT only accepts crashes involving a motor vehicle in transport [S5].
The store's incident report, handwritten and electronic versions	The business; a difference between versions is a lead to investigate, not proof of falsification.

4. Is the lot privately owned or government owned?

"Public" can mean open to customers or owned by a government, and only the second one brings in immunity and the Texas Tort Claims Act.

Lot	Usual legal frame
Privately owned shopping-center lot open to everyone	Private premises law; open access doesn't make it government property.
City garage or city surface lot	The Tort Claims Act. Parking facilities are listed as a municipal governmental function in CPRC §101.0215(a)(25) [S19].
University, hospital district, transit or airport lot	Investigate the owner, the operator and any private contractor; mixed arrangements are common.
Any lot where the pay-station sign names a company	That company may only process payments, not maintain the pavement or lights.

If a government entity may be involved, move this to the top of the list on day one.

Tort Claims Act rule	What it says
Notice deadline	Notice must reach the governmental unit within six months after the incident, describing the injury, the time and place, and the incident (CPRC §101.101(a)) [S19].
City charters	A city's charter or ordinance notice period is ratified and can be shorter (§101.101(b)).
Actual notice	Written notice isn't required if the unit had actual notice of the injury (§101.101(c)), but an incident report alone shouldn't be assumed to prove it.
Premise defect duty	For a premise defect, the government owes only the duty a private owner owes a licensee, unless the claimant paid for use of the premises (§101.022(a)).
Special defects	That licensee limit doesn't apply to the duty to warn of special defects such as excavations or obstructions on highways, roads or streets (§101.022(b)). A pothole in a lot isn't a special defect just because someone was hurt or because it's on public property.
Damages caps	State government and municipalities: $250,000 per person and $500,000 per occurrence for bodily injury, $100,000 for property. Other units of local government: $100,000, $300,000 and $100,000 (§101.023). These are statutory limits, not insurance limits.

Immunity, the statutory waiver in §101.021, premise-defect classification, discretionary decisions and the caps are separate questions. An ordinary-looking file can lose its government claim while everyone waits on a property manager's reply.

Who	Task
The client	Mention any agency name, campus or city sign at the first call.
Counsel	Calendar the six-month date (and any charter date) before working on a routine demand.

5. Who could be responsible, and how do you sort them out?

Make a responsibility matrix before naming anyone, because the best-known business isn't always the right defendant.

Possible party	Evidence of a connection	Question to answer
Driver and employer	Video, damage, dispatch records	What movement caused the contact?
Owner, tenant or parking operator	Deed, lease, common-area agreement	Who controlled this aisle or walkway?
Property manager	Management contract, complaint log	Who received complaints and approved repairs?
Paving, lighting or landscaping contractor	Work orders, invoices, photos	What work touched this spot?
Security company	Post orders, incident logs	What was the guard assigned to do?
Design professional	Plans and service agreements	What professional act is alleged?

The matrix is an investigation list, not a list of people to sue. A tenant with no control over the lot may not belong in the case.

Ask	Why it matters
Who could authorize a repair?	Control often follows authority, not title.
Who received complaints?	It may show knowledge.
Who placed the barriers?	It may identify the contractor or manager.
Who could close the route?	It shows who could have prevented the injury.

New names surface as records come in: the lease names a manager, the manager's file names a maintenance company, the work order names a subcontractor. Each new name raises deadline, pleading and service questions right away.

Two opposite errors	The matrix prevents
Assuming the big store is the only defendant	Missing the manager or contractor who actually controlled the hazard.
Assuming everyone connected to the parcel is liable	Suing parties with no supported connection to the event.

6. How do you prove the driver was negligent?

Prove the driver's case on its own evidence: what the driver could see, where you were, and whether there was time to avoid you.

Driver conduct	Evidence
Backing without looking	Rear-camera footage, witness views, impact point.
Looking at a phone	Video, admissions, phone records where obtainable.
Speed too fast for the lot	Damage, distance, video timing.
Turning without checking the crosswalk	Vehicle positions, sightlines.

Don't assume every car stored useful event-data-recorder information; the vehicle, the system, the trigger and retention all need checking. Avoid claims that a low-speed impact can't hurt anyone, or always causes serious harm.

Traffic law in a parking lot	What it means
Transportation Code ch. 550	It applies to a private access way or parking area a business provides for clients or patrons, not only to public highways (§550.001) [S29].
Other statutes	Some have geographic limits, so check each one.
No ticket	It doesn't defeat a civil claim.
A ticket	It doesn't prove every element, medical causation or anyone else's fault.

For more on fault between drivers, see who is at fault in a parking lot accident. If you were a pedestrian, the firm's Dallas pedestrian accident lawyer page covers related issues.

If the driver was working	Investigate
Delivery van, rideshare or company truck	Employment, scope of work, vehicle ownership, dispatch logs.
A logo or an app screen	It's a lead, not proof of employment.
Your own position (pedestrian, passenger, driver, getting in or out of a car)	It changes the issues and the insurance available.
A property condition that also looks important	Keep a separate proof plan for the driver anyway.

7. What duty does the property owner owe you?

A business owes a customer (an invitee) reasonable care about conditions it knew or should have known posed an unreasonable risk, but it owes a licensee much less.

Your status	What you must usually prove about the owner's knowledge
Invitee (for example, a customer parking to shop)	The owner had actual or constructive knowledge of a condition posing an unreasonable risk, failed to use reasonable care to reduce or eliminate it, and that failure proximately caused your injury.
Licensee (for example, someone on the property with permission but for their own purposes)	The owner actually knew of the dangerous condition, you didn't, and the owner failed to warn you or make it reasonably safe. Constructive knowledge isn't enough (State Dep't of Highways & Pub. Transp. v. Payne, 838 S.W.2d 235 (Tex. 1992)).
Someone in a restricted work area	Status, access and instructions need their own analysis.

Don't assume everyone in a lot has the same status. Your reason for being there, signs, instructions and any payment all matter.

Control question	Hypothetical answer
Does control require owning the land?	No. Control can extend beyond title but must relate to the area or function involved [S10].
Is a manager who arranges landscaping responsible for moving cars?	Not automatically.
Can an owner keep some duties after delegating others?	Yes; the contracts and actual conduct decide it.
Can a warning satisfy the duty?	It can. An adequate warning may satisfy the duty without eliminating the condition [S9].

Austin v. Kroger Texas, 465 S.W.3d 193 (Tex. 2015), explains the general rule on known or open-and-obvious hazards and its limited exceptions, including necessary use [S9]. Austin involved an employee, so it's cited here as general premises law. A duty problem isn't always solved by assigning comparative fault.

Who	Practical question
The client	What was this business legally required to do in these circumstances?
Counsel	Identify the duty before investing in a breach theory. A better maintenance practice doesn't create liability if there was no duty or an exception applies.

Broken concrete wheel stop with an exposed anchor bolt next to a tape measure

8. Was the pavement condition unreasonably dangerous?

A premises claim needs a specific condition, because "unsafe lot" is too vague to inspect or prove.

Name the condition	Photograph
Depression or pothole	A close shot with a scale and a wide shot showing the walking route.
Raised edge or broken wheel stop	Height, location and lighting.
Exposed anchor bolt	Whether it sat in the path to the store entrance.
Missing drain cover, slope or drainage path	The flow path and nearby features.

Measurements need a method, a location and conditions. A ruler set at a different spot can create a misleading comparison.

United Supermarkets v. McIntire, No. 21-0208 (Tex. June 17, 2022) (per curiam) [S7]	What it means
What the court held	The small parking-lot divot in that case wasn't unreasonably dangerous on that record; the Dallas court of appeals was reversed and summary judgment reinstated.
What it didn't hold	It didn't decide whether a larger or differently placed condition could be unreasonably dangerous.
The practical lesson	There's no rule that every minor irregularity is actionable, and no single measurement below which every condition is safe.

An expert should explain why this feature mattered given its location, visibility and use. "It could cause injury" doesn't answer whether the risk was unreasonable, and any cited code must apply to the site, the work, the date and the use.

Who	Task
The injured person	Describe the contact or slip you remember before anyone suggests a defect.
Counsel	Check the mechanism against footwear, mobility aids, vehicle geometry, photos and witnesses.

9. How do you prove the owner actually knew?

Actual knowledge comes from evidence that someone knew about this specific condition before the injury: a complaint, a staff observation, a service request, an inspection note or a repair attempt.

Knowledge chronology	Hypothetical entry
Source and recipient	Tenant's assistant manager emailed the property manager.
Date and content	October 3: "Bolt sticking up by the second light pole in row C."
Follow-up	Work order opened October 10, approved October 17, completed October 24.
Gap to examine	Three weeks between complaint and repair.

A general note that the lot "needed maintenance" may not show knowledge of the feature that hurt you. Tie each report to the same condition and location.

Witness says	Follow-up
"The hole had been reported."	Who reported it, when, and where is the record?
"That drain always backs up."	Same walking route? Did the operator get the information?
"It looked old."	What's the factual basis?
An employee who learned of it after the fall	Don't treat that as advance knowledge.

Keep exact wording instead of a stronger paraphrase, and plan who can authenticate each record. A dated maintenance reply or an earlier photo often proves more than "everyone knew the lot was dangerous."

Evidence	Strength
A named person told about an identified problem before the injury	Strong.
A general history of complaints elsewhere on the site	Weak unless tied to this spot.

10. How long was the hazard there?

Constructive notice asks whether the condition existed long enough that reasonable care would have found it, and for a temporary hazard like a puddle you need evidence of how long that specific condition was there.

H-E-B, L.P. v. Peterson, No. 24-0310 (Tex. Apr. 10, 2026) [S8]	Detail
Setting	A shopper slipped on a puddle after rain.
Evidence offered	Earlier roof leaks elsewhere, a heightened rain-inspection routine, and no employee walking the aisle for about two hours.
Holding	That evidence didn't show how long the puddle had existed, so summary judgment for H-E-B was reinstated.
Lesson for a lot	General prior problems and inspection habits don't replace proof about the specific hazard's duration.

A structural defect that sat for months is proved differently from a fluid spill that could form in seconds.

Clue	Caution
Dark, dried edges on an oil stain	May suggest age, but needs an explanation.
Footprints or cart tracks through liquid	Could have happened quickly.
A large area of water	A recent spill can be large.
Tire marks	Can appear in moments.

Build a worksheet: each time inference, the evidence for it, and the competing account. If the proof equally fits a spill moments earlier, identify what would tell them apart. A missing record isn't proof the hazard sat for hours.

Who	Why it matters
The injured person	It explains why earlier footage and witnesses matter even when the injury is obvious.
Counsel	Test the weakest timing inference early, before intake, demand and filing decisions.

11. Do the owner's maintenance policies set the legal standard?

No. Inspection schedules, work orders and cleaning logs can show timing, witnesses and contradictions, but an internal policy doesn't automatically create a higher legal duty.

Record	Ask
The written policy	Which version was in force on the injury date?
A checklist entry	Was it an inspection, a scheduled task, a completed repair or a later supervisor review?
Electronic logs	Were entries automatic or batch-entered at the end of a shift?
A missing form	It doesn't by itself prove every premises element.

Compare the paper system with what people actually did. Receiving complaints and performing repairs are often different jobs.

Practice question	Hypothetical answer to test
Who walked the lot, and which rows?	The night porter covered rows A to D only.
What triggered escalation?	Any trip hazard over a set size, by the manager's account.
Who could close a route or set out cones?	Only the property manager.
How did tenant and customer complaints enter the system?	By email to a shared inbox.
What did the contractor's scope cover?	Weekly sweeping, not drainage redesign; a recurring repair invoice identifies a problem without proving that repair was negligent.

"The lot was inspected" should start questions, not end the case. The goal is to show what happened at this site, not to put the business's whole maintenance program on trial.

Who	Use
The client	Ask what the inspection records actually show.
Counsel	Use policy evidence to find the relevant observation or action and to test credibility.

12. Can a paving or repair contractor be liable?

Yes, if it did negligent work, left an active work zone poorly protected, or controlled the condition that caused the injury, but its name on an invoice doesn't prove causation.

Preserve	Why
Before-and-after photos	Shows what the work changed.
Plans, work orders and change orders	Defines the actual task, location, date, crew and materials.
Inspection notes and acceptance emails	Shows open defects at handover.
Later work by others	Another party may have changed the condition after the contractor left.

An exposed elevation change could come from unfinished work, a design instruction, later wear or something else. Each needs proof.

Case	Rule
Strakos v. Gehring, 360 S.W.2d 787 (Tex. 1962) [S11]	A contractor isn't immune just because its work was completed and accepted by the owner. That doesn't make contractors strictly liable; duty, breach, causation and damages still need evidence, and later statutes or defenses may apply.
United Scaffolding, Inc. v. Levine, 537 S.W.3d 463 (Tex. 2017) [S10]	A claim against a contractor over a condition it controlled sounded in premises liability, and a general-negligence jury question couldn't support the verdict.
CPRC ch. 16 [S15]	Repose periods can bar claims against those who design or build improvements to real property (§§16.008, 16.009), separate from the two-year limit.
CPRC ch. 150 [S20]	A claim arising from a licensed architect's or engineer's professional services generally needs a certificate-of-merit affidavit filed with the complaint (§150.002).

Tell your lawyer about any work you saw: barriers, vehicles, workers, a temporary route. Those details identify the contractor and the stage of work. A construction-related injury doesn't automatically belong only against the owner or only against the contractor.

Hypothetical fact	What it suggests
Cones placed past the trench, not before it	The warning may not have reached people entering the route.
A crew left at 5 p.m. with the patch unfinished	Look at the contractor's control of the work area.

13. Did the lot's design, striping or sightlines cause the crash?

A design claim has to name the specific conflict, because "poor design" isn't a duty or causation analysis.

Hypothetical conflict	Records to get
A monument sign blocks the view of the exit lane	Site plan, as-built drawings, permits.
A re-striping project routed shoppers through a backing area	Later modifications and the contractor's scope.
Faded crosswalk paint	Maintenance history; fading is often a maintenance issue, not a design one.
A delivery truck parked in the fire lane blocked the view	Delivery schedules and the store's practice.
The crash happened on the public street next to the lot	HNMC, Inc. v. Chan, No. 22-0053 (Tex. Jan. 19, 2024): a hospital owed only a limited premises duty for the parts of the county right-of-way it controlled, and there was no evidence a condition it controlled caused the death [S12]. Owning nearby parking doesn't make a business responsible for every street crossing.

An original layout claim may involve different parties and deadlines than a maintenance claim.

The expert should separate	Example
An enforceable requirement	A code provision that applied to this site when it was built or altered.
A professional standard	A widely accepted design practice.
A recommended improvement	A better layout that wasn't required; it doesn't prove the actual layout breached a duty.
Chapter 150	If the claim targets a licensed design professional, the certificate-of-merit affidavit must be filed with the complaint; don't plan around the exceptions [S20].

Connect the design failure to the sequence. Explain how the proposed fix would have changed the crash or fall, with defensible assumptions about speed, visibility and movement.

Who	Task
The injured person	Preserve the route and what blocked the view, instead of claiming the whole lot violated code.
Counsel	Drop a design theory that can't explain the causal link, even if the lot could be better.

14. Do warning signs or an obvious hazard end the claim?

Sometimes, but not automatically: an adequate warning can satisfy the owner's duty, and an open-and-obvious hazard can defeat it, subject to narrow exceptions such as necessary use [S9].

Warning fact	What it may mean
A barricade placed beyond the hazard	It may not warn someone entering the route.
A cone photographed after the fall	It may not have been there before.
Small lettering at night	Visibility and wording matter.
A sign about a different condition	It may not relate to the hazard at all.

Disclose what you knew. A person who saw the hole and walked on presents different issues from someone who couldn't see it, and a client should never deny seeing something a video shows.

Necessary-use questions	Hypothetical
Was there another reasonable route?	A second exit was 40 feet away.
Is a shortcut the same as a necessary route?	Usually not.
Did a mobility device limit the choices?	A wheelchair user's only ramp was blocked; document the difference.
Should the owner have expected harm despite awareness?	Look at instructions, barriers and how the route was used.

A duty defense can stop the claim entirely, so it isn't just a percentage adjustment. Finish the legal analysis before assuming a jury will sort out visibility through fault allocation.

Who	Task
The client	Draw the route and the alternatives you considered.
Counsel	Test that account against site evidence and testimony.

15. Was it rain, a drainage defect or a spill?

Find out which, because ordinary rain, an unnatural discharge, a leaking system, a recent spill and a defect that pools water are treated differently.

Possible source	Records to preserve
Rain	Weather data for the hour of the fall.
Irrigation overspray	Sprinkler schedules and service tickets.
A drainage defect that concentrates water	Photos of the flow path, drainage complaints on this route.
A vehicle's fluid leak	Video of nearby cars; stain photos.
Cleaning residue	Cleaning logs and vendor records.

A puddle after a storm doesn't prove a defective drainage system. A drainage complaint elsewhere on the site may not matter unless it connects to this route.

Testing	Caution
Slip-resistance testing	Results depend on surface, contamination, footwear and method.
A dry test long after cleanup	May not describe the surface that day.
A wet demonstration	Must never be presented as footage from the incident.
Natural conditions like ice or mud	Need their own analysis; ice, mud, water and oil aren't one legal category.

Ask whether human activity changed the condition and whether there's evidence the responsible party knew. A continuing leak management knew about and a car's fresh oil drip are different cases, with different defendants, notice proof and experts.

Who	Task
The client	Describe look, smell, texture, source and location only if you observed them.
Counsel	Get the records that tell competing mechanisms apart.

16. How do lighting and security claims differ?

Poor lighting can hide a pavement hazard or a pedestrian from a driver, while a security claim is about a crime, and a broken light doesn't prove a different precaution would have stopped an assault.

Visibility claim	Investigate
Lamp operation and controls	Outage logs and repair tickets.
Shadows and glare	A night inspection under similar conditions.
Photos	Automatic exposure can make a scene look brighter than people saw it; keep camera settings.
The person's approach	Where they walked and what they could see.

For an assault, the questions are the developing incident, earlier crimes, knowledge, possible precautions and causation.

UDR Texas Properties, L.P. v. Petrie, 517 S.W.3d 98 (Tex. 2017) [S13]	Detail
Facts	An assault in an apartment complex parking lot.
Rule	Foreseeability and whether the risk was unreasonable are separate duty questions.
Lesson	A neighborhood crime count doesn't prove every element.
Security contract	Get the scope and what guards actually did; a sudden attack raises different causation questions than a long disturbance several people watched.

Define the precaution and how it would have prevented the harm. An expert who only says "more security would have helped" doesn't answer duty or preventability. See the firm's Dallas negligent security lawyer page for more.

Who	Task
The client	Preserve police information, messages, witness details and recordings; raise any ongoing safety concern through the right channel.
Counsel	Tie the alleged precaution to the actual facts, including limits and other explanations.

17. Do accessible parking rules apply to your fall?

They may, but only if the federal or Texas accessibility standards actually apply to that feature, which depends on scoping, construction or alteration history and the facility [S27, S28].

Feature	Technical issue
Accessible spaces and access aisles	ADA section 502.4: aisles at the same level as the spaces; slopes not steeper than 1:48, about 2.08 percent [S27].
Curb ramps and routes	Separate requirements; check scoping first.
Vehicle overhangs	Can block a route and force a detour into traffic.
Any other lot surface	The 1:48 limit isn't a maximum slope for every surface in every lot.

A gap a walker steps over can stop a wheelchair. Document the person's route and mobility aid; age or disability alone doesn't prove negligence.

Access claim versus injury claim	Difference
Civil-rights access claim	Its own standing rules, elements and remedies.
Negligence claim for injury	Duty, breach, causation and damages; a violation doesn't automatically resolve it.
Advisory text in a standard	Not the same as a mandatory provision.
An inapplicable code citation	Can undermine an expert report.

Photograph the full route, the access aisle, the entrance and the obstruction. Counsel should get qualified measurements, plans and alteration records.

Who	Task
The client	Photograph where you parked and every step to the door.
Counsel	Confirm the standard applied to this feature on this date before relying on it.

18. How do you preserve surveillance video and dashcam files?

Send targeted preservation requests quickly to everyone who may control footage, naming the site, date, location, event and a time window that covers the period before the fall or crash.

Possible custodian	What they may hold
The store or tenant	Entrance and parking-lot cameras.
Property manager or parking operator	Pole cameras, gate logs, pay-station records.
Neighboring businesses	Cameras that catch part of the lot.
Security contractor	Patrol logs and body cameras.
Drivers and vehicle owners	Dashcam and rear-camera files.

There's no universal retention period for Texas parking facilities. Find out who can stop overwriting, export files and explain the system. One letter rarely reaches everyone.

Handling rule	Why
Get native files and the player software	A phone video of a monitor loses resolution, frames and image area; it's a lead, not the best evidence.
Work from copies; keep metadata	Protects authenticity.
Record who supplied each file	Supports authentication later.
Note clock differences	A payment record anchors time but doesn't prove the fall happened at that second; a gate log shows a car, not the driver.

Keep your own photos, messages and posts, including unfavorable ones. Deleting or altering evidence damages a claim.

Step	Track separately
Preservation	Saved from deletion.
Production	Actually received.
Authentication	A witness who can explain the file.
Review	Someone has watched it and noted what it shows.

19. What if the video or other evidence is gone?

Missing evidence can matter, but it doesn't prove negligence, and Brookshire Brothers, Ltd. v. Aldridge, 438 S.W.3d 9 (Tex. 2014), sets the Texas framework [S14].

Brookshire Brothers rule	Detail
Who decides	The trial judge decides whether there was a duty to preserve and a breach, and picks the remedy.
Remedy	It must be proportionate to the harm.
Spoliation instruction	Reserved for intentional spoliation, or negligent loss that left the other side without a meaningful ability to present its claim or defense.
Facts	The store kept about eight minutes of video and the rest was overwritten; the instruction given was an abuse of discretion.

Build the chronology before asking for relief: when a claim became foreseeable, why the evidence mattered, who controlled it, what steps were available, and how it was lost.

Problem	It may really be
"Destroyed"	Delayed production.
"Missing"	An unreadable format or incomplete export.
"Refused"	A scope objection that can be narrowed.
"Overwritten"	Confirm the real settings; systems don't all overwrite on the same cycle.

Explain prejudice specifically: what the surviving footage doesn't show and whether witnesses or records fill the gap. Don't claim to know the missing material favored your client.

The claimant's own duty	Keep
Physical items	Shoes, mobility aids, damaged property.
Digital items	Original photos and messages; a party seeking sanctions is more credible after caring for its own evidence.

20. What deadlines apply to a Texas parking lot claim?

Texas generally gives two years to file a personal-injury lawsuit (CPRC §16.003), and a government claim can require written notice within six months or less [S15, S19].

Deadline	Rule
General limitations	Two years, subject to accrual, disability and other exceptions [S15].
Government notice	Six months under §101.101(a); a city charter can set a shorter valid period; notice must go to the right entity by a proper method [S19].
Repose for design and construction	Separate from limitations (§§16.008, 16.009) [S15].
Certificate of merit	Filed with the first complaint against a covered design professional [S20].
Chapter 95	Applies to certain claims by contractors' workers; don't apply it to a customer's injury by default [S21].

A demand letter, an incident report or an open insurance claim doesn't normally extend the filing deadline, and treatment doesn't have to end before a protective lawsuit is filed. See the firm's guide to the two-year filing deadline.

Deadline memo item	Hypothetical entry
Event date	March 14.
Government involvement	City garage; notice date September 14 at the latest, and check the charter for a shorter period.
Parties and service plan	Driver served first; property manager identity pending.
New entity found later	Assess the consequences that week, not at the next routine review.
Police presence or an employee knowing	Not assumed to satisfy government notice.

Tell your lawyer about prior lawyers, offers and any paper mentioning dates. After filing, service has to be tracked and failed attempts fixed.

Who	Task
The client	Bring every letter, offer and court paper.
Counsel	Keep independent calendar controls and internal filing targets.

21. Which insurance policies might pay?

Several may: auto liability, commercial auto, general liability, umbrella or excess, professional liability and your own coverage, but finding a policy doesn't prove fault and proving fault doesn't guarantee coverage.

Policy	Notes
Texas auto minimum	$30,000 per person, $60,000 per accident and $25,000 property damage, called 30/60/25 [S25]. It's a floor, not a typical settlement or a cap on damages.
Driver's actual policy	Check the named insured, permissive use and any employer coverage.
Commercial general liability	Get the policy, endorsements, insureds, dates, retentions and excess layers [S26].
Umbrella or excess	TDI explains excess sits above CGL limits and umbrella sits above auto and CGL [S26].
Certificate of insurance	Not a substitute for the policy terms.
Additional-insured and indemnity terms	May shift who pays between businesses.

Exclusions and conditions matter when vehicles, professional services, completed work or employee injuries are involved. A claim number doesn't mean a loss is covered.

Ask your lawyer to separate	Why
Claimed harm	What you lost.
Legally supportable damages	What the law allows.
Available insurance	What policies may pay.
Likely collectible recovery	What can actually be collected; never assume a "standard million-dollar parking lot policy." See the firm's guide to policy limits.

22. What if the driver had no insurance or drove off?

Your own policies may help: uninsured or underinsured motorist, personal injury protection, medical payments or health insurance, depending on who you were and what the policy says [S25].

Coverage	What it usually does
UM/UIM	Pays when the at-fault driver has no or too little insurance, under the policy's terms.
PIP	Pays certain medical and wage losses regardless of fault, if purchased.
Collision	Pays for vehicle damage, not bodily injury.
Health insurance	Pays treatment but may seek reimbursement later.

TDI's guide describes UM/UIM, PIP and the written-rejection rules for offered coverage. Read the actual policy and endorsements, not the renewal summary; a pedestrian and a vehicle occupant can have different coverage.

Step	Why
Give timely notice to your insurer	Policies have notice conditions.
Preserve evidence identifying the unknown car	Plates, video, paint transfer.
Get advice before signing any release	Consent, settlement, exhaustion, subrogation and offsets can affect other claims.
Bring declarations pages and rejection forms	You don't need every page before asking for advice; list household and employer vehicles.

23. How do you prove the injury and the medical bills?

Medical records must explain the injury and its link to the event, and a bill proves a charge was made, not that the parking lot event caused every service.

Expense exhibit column	Hypothetical entry
Provider and date	Orthopedic clinic, April 2.
Service	Wrist X-ray and splint.
Charged, paid and adjusted	$1,140 charged; $410 paid by insurer; balance adjusted.
Still owed	$60 copay.

Texas limits recovery of medical expenses to amounts actually paid or incurred, so the raw total of original charges may not be the recoverable figure (CPRC §41.0105) [S17].

Rule	Meaning
CPRC §18.001 [S18]	An affidavit procedure about whether charges were reasonable and services necessary. It isn't evidence of causation.
Deadlines	Come from the statute and the court's orders; calendar them and any response to a counteraffidavit.
Earlier conditions, unrelated falls, later crashes	Disclose and analyze them; an aggravation claim needs an accurate baseline.
Unfavorable history	Leaving it out of a summary doesn't remove it from the case.

Keep explanations of benefits, receipts and collection notices, and tell your lawyer when a billing company changes. Reconcile the expense exhibit before negotiation and again before trial.

Who	Task
The client	Forward every new bill or balance notice.
Counsel	Remove duplicates and unrelated care before the number goes in a demand.

24. How are lost wages and future care proved?

Past lost wages need proof of time missed, pay and the medical reason you couldn't work, while future earning capacity and future care need their own support.

Loss	Evidence
Past wages	Payroll, attendance records, work restrictions.
Self-employed income	Records separating revenue, expenses, owner pay and unrelated business changes.
Future earning capacity	Restrictions, skills, work history, other available jobs; a vocational expert or economist when the facts justify the cost.
Future care	Medical recommendations and a defensible prognosis; a life-care planner organizes services but can't give medical opinions beyond that role.

Distinguish care that might be considered from care reasonably supported as a future need.

Avoid	Example
Double counting	Paying for a home aide and also claiming the same chores as a separate household loss.
Hidden assumptions	Projections must show the time horizon, rates and inputs.
Overstatement	Saying you can't do anything when you can do some tasks with limits.
A dramatic projection on weak facts	A well-supported modest figure often persuades more.

25. How do you show pain and lasting harm?

Pain, mental anguish, physical impairment and disfigurement are separate categories, and each needs concrete evidence instead of one undifferentiated number.

Hypothetical change	Who can describe it
Stopped driving at night after a head injury	Spouse.
Needed help bathing for six weeks	Adult daughter.
Missed a child's season of games	Coach or another parent.
Changed how a warehouse job is done	Supervisor.

Witnesses should describe what they saw in their own words, not repeat phrases supplied by a lawyer.

Evidence	Tip
Photos of bruising, casts or scars	Keep originals and dates.
A recovery journal	Record improvements as well as setbacks.
Attending an event while hurt	Explain how long you stayed and what help you needed; don't deny you went.
A "multiplier" of medical bills	No reliable universal multiplier values a Texas parking lot injury from bills alone.

Two people with similar bills can have very different lasting effects, and different liability proof changes the risk even for similar injuries. The amount requested should connect to the record and current damages law, not to unrelated verdicts or a company's size. The firm's claim value guide covers valuation in more depth.

Who	Question
The client	What evidence supports each category, and what's still uncertain?
Counsel	Is an opening demand being mistaken for a likely trial result?

26. How does shared fault change the recovery?

Under Chapter 33, if you're found more than 50 percent responsible you recover nothing, and at 50 percent or less your damages are reduced by your percentage [S16].

Hypothetical teaching figures	Result
Supported damages	$300,000.
Your share at 20 percent	Reduced to $240,000 before other legal adjustments.
Your share at 51 percent	Barred.
What these numbers are	Teaching figures, not case estimates.

Allocation can include defendants, settling persons and properly designated responsible third parties.

Who pays what	Rule
A defendant found more than 50 percent responsible	May be jointly and severally liable under the statute [S16].
Other defendants	Generally liable only for their own share unless an exception applies.
Settlement credits and contribution	Need careful treatment, as do indivisible versus separate injuries.
More policies	Don't multiply the injury's value; the same loss can't be paid twice.

Before accepting a partial settlement, review the release language, credits and coverage effects. One participant's payment may not resolve claims against the others.

Who	Question
The client	How does settling with one party change the rest of the case and my net recovery?
Counsel	Model the verdict outcomes with disclosed assumptions; the number of defendants doesn't predict the size of the recovery.

27. What goes into a strong demand?

A demand should explain the event, the parties, the legal theories, the condition or conduct, knowledge where required, the medical connection, the losses and the requested resolution, with an exhibit index a reviewer can follow.

Weakness	Address it this way
A visible warning	Explain the route and facts without denying the video.
Care started late	Give the supported chronology.
A prior condition	Show what changed, with evidence.
A ticket proves a complaint but not the defect's role	Keep documented facts, inferences and open questions labeled separately.

A demand that dodges the issue most likely to decide the case loses its value.

Multi-party issue	Check
Global or partial?	Which claims and parties would be released.
Other coverage	Whether a settlement affects another policy.
Time-limited demands	Governing law, the right recipients, the terms and a real chance to evaluate; a deadline doesn't automatically create extra-contractual exposure.
A key assertion without a source	Get the source, qualify the statement or revise the theory.

28. What should the lawsuit petition include?

The petition names the right defendants, jurisdiction, venue, the occurrence, the supported claims and the relief, without lumping driver, premises, professional and government claims into one allegation.

Pleading check	Hypothetical problem
Entity names	The sign says "Oak Plaza," but the operator is a separate LLC.
Owner versus manager	Two different companies at two addresses.
Successor or similar name	Don't substitute an affiliate without evidence.
Service	Track citation, attempts and returns.

Venue follows the facts. A Dallas law firm doesn't mean every Texas parking lot case belongs in Dallas, and government cases or federal removal add rules and a separate calendar.

Theory	Pleading requirement
Design professional	Chapter 150 certificate of merit with the first complaint [S20].
Government defendant	A supported waiver and jurisdictional facts.
Alternative theories	Allowed while evidence develops, but grounded in facts and updated as discovery narrows them.
Filing in general	Protects rights and opens formal discovery; it doesn't mean the case will be tried.

29. How should discovery be organized?

Start with an element-and-evidence chart that names the witness, record, recording, item or expert needed for each disputed point, and request first what's most likely to change the assessment.

Theory	Discovery priorities
Driver	Movement, visibility, employment, vehicle data.
Premises	Control, condition, notice, warnings.
Contractor	Scope, performance, completion, later changes.
Government	Focused jurisdictional discovery.

Use document production to pick depositions, and depositions to find missing records. If a witness mentions an unproduced drainage complaint, follow it.

Rule	What it covers
Texas Rules of Civil Procedure [S22]	Scope, proportionality, privilege, disclosures, nonparty discovery and supplementation.
Rules 192.3(f) and 194.2	Insurance and indemnity agreements.
Admissibility	Discovered material isn't automatically admissible at trial.
Proportionality	A catastrophic case can justify broad work; a smaller claim needs a narrower plan.

30. How are witnesses and company representatives prepared?

A frontline employee speaks from personal knowledge, while a company representative testifies on designated topics from the organization's preparation, so match each issue to the right witness.

Witness	Cover
Night porter or maintenance worker	Role, shift, area, inspection method, timing and how the time is remembered.
Company representative	Common-area control, complaint systems, maintenance, contractor selection where at issue, video exports, policy records.
The claimant	The event, prior conditions, treatment, limits and work; preparation isn't memorization.

A truthful "I don't remember" beats a guess that conflicts with the record.

Claimant tip	Why
Listen and answer only the question	Deposition testimony is evidence.
Ask for clarification	A confused answer can be used later.
Discuss photos and social media in advance	Ordinary activities can then be explained in context.
Separate personal knowledge from assumptions	The record has to be reliable.

31. When do you need an expert?

Hire an expert when a material question needs specialized knowledge, not to build an impressive roster.

Discipline	Typical inputs
Lighting	Night measurements and fixture history.
Accident reconstruction	Vehicle positions, dimensions, recordings, movement assumptions.
Pavement engineering	Surface measurements, construction records, condition history.
Medicine, vocational, economics, life-care planning	Records, restrictions and supported assumptions.

Plan inspections lawfully, document conditions and methods, and give notice before destructive testing.

Report review	Look for
Assumptions	Facts nobody observed or recorded.
Scope	Opinions outside the expert's field.
Alternatives	Competing explanations not considered.
Standards	Whether the cited standard applied on that date; Rule 702 needs more than a credential, and disclosure deadlines apply [S24].

32. How do you prepare for summary judgment?

Develop the evidence from day one around the issues most often challenged: duty, control, unreasonable risk, notice, causation, immunity, professional-claim requirements and limitations.

Response file	Contents
Exhibits	Authenticated documents and recordings.
Testimony	Deposition cites and declarations based on personal knowledge.
Connections	A note linking each item to the legal point it proves.
A big production in a folder	Not the same as evidence ready to file.

For motions filed on or after March 1, 2026, the amended Rule 166a generally requires a response within 21 days after the motion is filed, unless the court grants leave or the parties agree [S22, S23]. Check the court's orders and calculate every deadline rather than relying on the old hearing-based shorthand.

If evidence is still missing	Do
Ask for relief	Say exactly what's missing, why it matters and what you did to get it.
Independent grounds	Answer every ground; one unanswered ground can support judgment.
Objections and rulings	Preserve them for any later review.
For the client	A motion tests legal sufficiency; it isn't a finding that you made anything up.

33. How should mediation be approached?

Go to mediation when the key evidence and uncertainties can be explained, with a short liability analysis, a current damages summary, a coverage chart and a list of open issues.

Net-recovery worksheet (hypothetical)	Line item
Gross settlement	The amount offered.
Attorney's fee	Calculated under your written fee agreement.
Case expenses	Filing fees, records, experts and similar costs.
Medical balances, liens and reimbursement claims	Health plan, hospital or other payment obligations.
Remainder	What you would actually receive; which figures are confirmed and which are still estimates should be marked.

Different terms, calculation order, open balances or reimbursement outcomes change the remainder. Ask your lawyer to walk through it before you decide.

Decision point	What to understand
Partial settlement	Release scope, credits, remaining claims and coverage effects.
Global settlement	Who is released and what obligations survive.
Trial risk	The strongest defense, added cost, delay and collection uncertainty, explained without pressure.
Who decides	Settlement authority belongs to the client under the professional rules.

34. How is a case prepared for trial?

Draft the jury charge early so it exposes missing proof, because a premises theory needs different findings than a driver-negligence theory.

Issue	Who proves it
Control	Property manager or lease witness.
Condition or movement	Eyewitness and video.
Advance knowledge	Complaint records and employees.
Causation and loss	Qualified medical and economic witnesses.

Label reconstructions, animations, diagrams and later photos accurately. A visual explains a theory; it doesn't prove its own assumptions.

Rule	Lesson
Levine [S10]	General-negligence findings can't support recovery when premises findings are required.
Charge and preservation rules [S22]	Requests, objections and rulings must be made correctly.
Opening and closing	Forecast admissible evidence, then connect it to the questions asked.
Emotion	Anger at a big owner or sympathy for the injured person can't replace required findings.

35. What happens in jury selection?

Jury selection looks for fixed bias and whether jurors can follow the court's instructions, such as a belief that every pedestrian should watch the ground or every backing driver is at fault.

Good practice	Avoid
Open questions that invite explanation	Scripted follow-ups before listening.
Separating experience from a fixed rule	Striking a juror just for managing property or having fallen.
Asking whether jurors can assess several actors separately	Commitment questions tied to disputed facts.
Asking about willingness to consider legal damage categories	Mentioning insurance or who will pay.

The goal is a fair panel, not advance agreement with your theory. Jury selection doesn't guarantee sympathy.

Who	Expectation
The client	Jurors will hear facts that favor the defense too.
Counsel	Connect questions to real issues without arguing the case early.

36. Is a verdict the same as money collected?

No. The court enters judgment after post-verdict issues, and motions, appeals, settlement, coverage disputes and collection can change the timing and the final amount.

Stage	Watch
Verdict	Check it against the charge for inconsistencies and omitted issues.
Post-trial	Preserved objections and deadlines.
Appeal	A realistic assessment, not a promise.
Collection	The defendant, insurance, assets, statutory limits and procedures.

A large verdict in an unrelated parking lot case says nothing about this one.

When results are discussed publicly	Rule
Settlements, verdicts, judgments and amounts collected	Keep them distinct.
Results by other lawyers	Never present them as Aaron Herbert's history [S30].
The credential	Can be stated without inventing a parking lot outcome [S1].
For people choosing a lawyer	Ask what an advertised figure means and what limits its relevance.

37. What do parking lot statistics actually show?

Public sources don't give a count of every Texas parking lot, an annual census of injuries in them, or an average Texas parking lot settlement, and that gap doesn't mean such injuries or settlements are rare.

Source	What it shows and doesn't
National Safety Council [S2]	Tens of thousands of parking lot and garage crashes a year nationally. In an NSC poll, 66 percent of drivers said they'd make calls and 56 percent said they'd text while driving through lots. Those are self-reported national intentions, not Texas crash causes.
NHTSA non-traffic data [S3]	Includes events outside parking lots, so its totals aren't parking lot totals.
TxDOT crash reporting [S4, S5]	Separates crashes that stay inside a lot from those starting on a roadway; roadway totals aren't a lot-injury census.
Census NAICS 812930 [S6]	Covers businesses mainly providing parking or valet service, not every physical lot.

Combining these into a precise Texas injury rate would need data and assumptions nobody has established.

Figure	What it isn't
Auto minimum 30/60/25	A general liability limit [S25].
A contract's required coverage	Proof the coverage was bought or applies.
Government caps	An insurer's declarations; they're statutory limits with conditions [S19].
The numbers that matter most	Your bills, lost work, condition history, actual coverage and proposed net recovery.

38. Hypothetical: a backing van, a paving detour and a fracture

A customer walks from an accessible space toward the store, follows a temporary detour around paving work, and a reversing van breaks her ankle.

Fact	Question it raises
Video shows the driver glancing at a phone while backing	Supports the driver claim.
The detour sends pedestrians behind parked cars and blocks the usual route	Control, duty and causation for the contractor and manager.
An accessible alternative existed or didn't	Accessibility and route analysis.
Records	Work orders, barrier plans, management emails and the actual layout.

Neither fact excuses investigating what each party did.

Change the facts	Effect
The contractor worked on the opposite side of the lot, and she chose her own route	The contractor theory weakens though the injury is the same.
The manager ordered the same detour after a complaint about van traffic there	The premises claim may strengthen materially.
The tenant had no control over the common area and no role in the detour	Naming it just because she shopped there may be unjustified.
The result	Allocation and coverage follow the proof, not the number of possible defendants.

39. Which evidence decides the next step?

Use an evidence audit to show which issue currently limits the evaluation and what would resolve it.

Issue	Useful evidence	Decision it informs
Event mechanism	Original video, witness accounts, scene records	Which theories fit.
Parties and control	Deeds, leases, management and work agreements	Who had authority or conduct.
Condition and risk	Photos, measurements, applicable standards	Whether the feature supports a claim.
Advance knowledge	Complaints, inspections, messages, earlier footage	What was known before the injury.
Causation	Movement analysis, clinical opinions, alternatives	Whether each failure contributed.
Loss	Reconciled bills, wage records, prognosis	Supported damages.
Insurance	Policies, endorsements, coverage letters	Sources of payment.
Government issues	Ownership, notice records, waiver analysis	Urgent action and jurisdiction.
Procedure	Deadline memo, service, orders	What must happen next.

Assign a person and a next action to every open item, and mark it requested, received, reviewed or disputed.

Review the audit before	Why
The demand	To avoid unsupported assertions.
Expert decisions	To define the questions.
Mediation and dispositive responses	To know the gaps.
Trial	Disproved assumptions should be gone by then.

40. Questions people ask about parking lot claims

Question	Short answer
Can both a driver and a property owner be responsible?	Yes, when separate supported failures contribute. The property claim still needs its own duty and causation proof; a crash in a lot doesn't prove owner negligence.
Can I sue an owner, a business and a contractor in one case?	Potentially, if each has a factual basis and joinder and jurisdiction rules are met. Several defendants don't mean repeated payment for the same loss.
Does a lease automatically protect the store or owner?	No. The lease is important, but control, retained duties and actual conduct matter too, and contract allocation between businesses is a separate issue from your rights.
What if the lot is free to use?	Free parking doesn't end a private premises claim. On a government lot, paying for use can change the Tort Claims Act duty (§101.022(a)).
What if the driver left and the pavement was also defective?	Preserve anything identifying the car, check your own coverage, and investigate the defect separately.
Is there a standard settlement for a fracture in a parking lot?	No. Liability, medical connection, lasting effects, expenses, defenses, coverage and collection all matter.
How long do I have?	Generally two years to sue, but government notice can be due within six months or less. Have the dates checked now.

41. Request a case review

Start with the exact location, date, what happened, your injuries, your treatment and the evidence you've kept, and tell the firm about any government involvement, prior lawyers, court papers or claim letters.

Next step	How
Online	Request a case review with The Law Firm of Aaron A. Herbert, P.C. Use the secure form for basic facts and don't post medical records publicly.
Phone	Call (214) 200-4878.
Questions to ask	How drivers, owners, operators and contractors would be investigated; who will communicate with you; how fees and expenses work under a written agreement.
Credential	Aaron Herbert is Board Certified in Personal Injury Trial Law by the Texas Board of Legal Specialization [S1].
Related practice pages	Dallas premises liability lawyer and Texas parking lot injury lawyer.

Guide	Status
Texas parking lot injury knowledge hub	Hub.
What to do in the first 72 hours after a Texas parking lot injury	Cluster.
Preserving video and physical evidence after a Texas parking lot injury	Cluster.
Who can be liable for a Texas parking lot injury	Coming soon.
Injuries in government-owned Texas parking lots	Coming soon.
Insurance and policy limits for Texas parking lot injury claims	Coming soon.
Filing a Texas parking lot injury lawsuit and preparing for trial	Coming soon.

Sources

Ref	Source
S1	State Bar of Texas, Aaron Alan Herbert, Bar No. 24036761.
S2	National Safety Council, Parking Lot Safety (viewed October 31, 2026).
S3	NHTSA, Non-Traffic Surveillance.
S4	TxDOT, Crash Reports and Records.
S5	TxDOT, 2025 Instructions to Police for Reporting Crashes (CR-100, version 29).
S6	U.S. Census Bureau, NAICS 812930 Parking Lots and Garages.
S7	United Supermarkets, LLC v. McIntire, No. 21-0208 (Tex. June 17, 2022) (per curiam).
S8	H-E-B, L.P. v. Peterson, No. 24-0310 (Tex. Apr. 10, 2026).
S9	Austin v. Kroger Texas, L.P., 465 S.W.3d 193 (Tex. 2015).
S10	United Scaffolding, Inc. v. Levine, 537 S.W.3d 463 (Tex. 2017).
S11	Strakos v. Gehring, 360 S.W.2d 787 (Tex. 1962).
S12	HNMC, Inc. v. Chan, No. 22-0053 (Tex. Jan. 19, 2024).
S13	UDR Texas Properties, L.P. v. Petrie, 517 S.W.3d 98 (Tex. 2017).
S14	Brookshire Brothers, Ltd. v. Aldridge, 438 S.W.3d 9 (Tex. 2014).
S15	Texas Civil Practice and Remedies Code ch. 16.
S16	Texas Civil Practice and Remedies Code ch. 33.
S17	Texas Civil Practice and Remedies Code §41.0105.
S18	Texas Civil Practice and Remedies Code §18.001.
S19	Texas Civil Practice and Remedies Code ch. 101 (Texas Tort Claims Act).
S20	Texas Civil Practice and Remedies Code ch. 150.
S21	Texas Civil Practice and Remedies Code ch. 95.
S22	Texas Rules of Civil Procedure (as amended October 1, 2026).
S23	Supreme Court of Texas, Misc. Docket No. 26-9012 (Rule 166a amendments).
S24	Texas Rules of Evidence (as amended July 2, 2026).
S25	Texas Department of Insurance, Auto Insurance Guide.
S26	Texas Department of Insurance, Commercial General Liability Insurance.
S27	U.S. Access Board, ADA Standards chapter 5.
S28	Texas Department of Licensing and Regulation, 2012 Texas Accessibility Standards.
S29	Texas Transportation Code ch. 550.
S30	Texas Disciplinary Rules of Professional Conduct.
Added	State Department of Highways & Public Transportation v. Payne, 838 S.W.2d 235 (Tex. 1992).