Dallas Motel Parking Lot Shooting & Wrongful Death Lawsuit — Attorney911 Holds the Motel Owner and Property Management Company for Failing to Prevent Foreseeable Gun Violence in High-Crime Areas, Ralph Manginello’s 27+ Years of Federal-Court Trial Practice, Lupe Peña the Former Insurance-Defense Attorney Who Knows How the Claims Machine Undervalues These Cases, We Preserve Surveillance Footage and Police Call Logs Before They Are Overwritten, Texas’s Wrongful Death Act and Comparative-Fault Rule, the Firm Has Recovered Millions in Negligent Security Cases — Free 24/7 Consultation, No Fee Unless We Win, Hablamos Español, 1-888-ATTY-911

Dallas Motel Shooting Lawyer: Holding Negigent Motel Owners Accountable When a Drive-By Becomes a Wrongful Death

The phone rings at a time no one is ready for. A daughter, a husband, a parent, a friend — someone is calling to say that your loved one was sitting in a car outside a Dallas motel, in a parking lot that was supposed to be ordinary, and a second vehicle pulled up and opened fire. One person is dead. Three more are injured. The police want statements. The hospital is calling. A reporter has already left a voicemail. And somewhere in a corporate office, an insurance company is already opening a file with your family’s name on it and a reserve number designed to make the case look small.

If that is where you are right now — or if you have been carrying that phone call for days or weeks — this page is written for you. We are Attorney911 — The Manginello Law Firm, PLLC. Ralph P. Manginello has been a Texas trial lawyer for 27+ years, including federal court; before law school he was a journalist, which is how he learned to investigate a story the way he now investigates a defendant. Lupe Peña is a former insurance-defense attorney — a 3rd-generation Texan from Sugar Land who spent years inside the rooms where claims like yours are priced, denied, and devalued — and now uses that knowledge for the injured. Lupe is fluent in Spanish and conducts full consultations in Spanish. We take commercial-premises, catastrophic-injury, and wrongful-death cases across Texas. The call that brings you to this page is exactly the kind of case we handle. We do not get paid unless you do.

The page below is the full expert analysis of what happened outside that Dallas motel, who owes what, what the law in Texas actually requires, what evidence is dying right now, how the insurance company is going to try to devalue your case, and what we do — in detail — to stop them.

The Texas Law That Governs This Case

The Timberwalk Foreseeability Test

The single most important Texas Supreme Court case in this area is Timberwalk Apartments, Inc. v. Cain, 972 S.W.2d 749 (Tex. 1998). Timberwalk is the case every negligent-security trial in Texas turns on. The court held that a commercial property owner has a duty to protect against criminal acts of third parties when the criminal act is foreseeable — and it identified five factors that decide foreseeability on any given property. The defense will tell you the shooting was “random” or “unforeseeable.” Timberwalk is the test that exposes that answer as a legal conclusion, not a fact.

The five Timberwalk factors are:

1. Proximity of prior crimes to the location of the new injury. How close — in feet, in blocks, in the same ZIP code — have similar crimes happened before? A motel that has had shootings, drug deals, assaults, or robberies in its own parking lot has a proximity problem the new owner or operator inherited when it bought the franchise. If the prior incidents were at a different property the same operator owned, the proximity argument only gets stronger.

2. Recency of prior similar crimes. A shooting three days before the deadly shooting is far more probative than one three years before. But the Texas cases do not require a precise recency window; older incidents that show a pattern are still relevant, particularly when the operator did nothing in response.

3. Frequency of prior similar crimes. A single prior assault is weaker than a documented series. Motel parking lots with high turnover, cash-paying extended-stay guests, and visible drug or prostitution activity generate police calls-for-service on a regular basis. The frequency question is answered by the motel’s own police-call history — and by the police-call history at any sister property run by the same operator.

4. Similarity between the prior incidents and the injury at issue. Drive-by shootings, armed robberies in the parking lot, and aggravated assaults on guests carry the most weight when the new incident is also a drive-by shooting. The closer the prior pattern resembles the new event, the harder the defense’s “no one could have predicted this” line becomes.

5. Publicity of the prior crimes. Did the prior incidents generate police reports, news coverage, or internal incident logs? A motel that received a written police advisory, that was on a city “chronic nuisance” list, or that had its own security log flagging suspicious activity has been told, in writing, that violence was foreseeable on its property.

“A property owner has a duty to protect against criminal acts of third parties if the criminal act is foreseeable. In determining foreseeability, courts consider, among other relevant factors, (1) proximity of the prior crimes to the location where the injury occurred, (2) recency of the prior crimes, (3) frequency of the prior crimes, (4) similarity of the prior crimes to the crime in question, and (5) publicity of the prior crimes.”
— Timberwalk Apartments, Inc. v. Cain, 972 S.W.2d 749, 756 (Tex. 1998) (summary of the duty framework).

A Texas jury that hears all five Timberwalk factors pointing toward the same motel will almost never return a defense verdict on duty. The fight in a Dallas motel shooting case is therefore not “did the motel owe a duty?” — it is “did the motel breach that duty?” and “did the breach proximately cause the death or injury?” Those are the two battles the evidence in this case is built to win.

The Texas Wrongful Death and Survival Statutes

Because the shooting claimed a life, two parallel Texas statutes apply:

• The Texas Wrongful Death Act, Tex. Civ. Prac. & Rem. Code §§ 71.001–71.004, gives the surviving spouse, children, and parents of the deceased a direct claim for their own losses — the financial support the decedent would have provided, the services the decedent would have rendered, the loss of companionship and society, and the loss of inheritance the decedent would have accumulated. The Wrongful Death Act belongs to the family, not to the estate.
• The Texas Survival Statute, Tex. Civ. Prac. & Rem. Code § 71.021, gives the decedent’s estate a separate claim for the decedent’s own pre-death conscious pain and suffering, mental anguish, medical and funeral expenses, and any lost earnings between injury and death. A survival claim requires evidence the decedent was conscious after being shot — that is a litigation focus we will explain further down.

A single death opens two separate claims. The defense will try to treat them as one. They are not.

Texas Proportionate Responsibility — the 51% Bar

Texas is a modified comparative-fault / proportionate-responsibility state under Chapter 33 of the Texas Civil Practice and Remedies Code. Every person whose fault caused the injury is on the verdict form, and each is assigned a percentage. Two consequences matter immediately:

• If the motel (and any co-defendants we name) is found 50% or less at fault, they pay only their percentage share. They are not jointly and severally liable for the rest.
• If the motel (or any single defendant) is found more than 50% at fault, that defendant becomes jointly and severally liable for the entire judgment — meaning the family can collect the full amount from that defendant, leaving the defendant to chase the other responsible parties for contribution.

In a shooting case, this often comes down to whether the jury blames the motel for failing to provide security or blames the shooter alone. In a drive-by at a commercial motel parking lot, where the motel is a paid premises that invited the public in, the motel will almost always take a substantial share of the verdict — and frequently the dominant share. That is what makes the 51% bar so important: it converts a proportionate responsibility state into something close to a joint-and-several regime for the negligent motel.

The Two-Year Deadline in Texas

The Texas statute of limitations is short and unforgiving. Under Tex. Civ. Prac. & Rem. Code § 16.003(a), a personal-injury claim must be filed within two years of the date the cause of action accrues — the date of the shooting. Under § 16.003(b), a wrongful-death claim must be filed within two years of the decedent’s death. Survival claims are subject to the same two-year deadline. If the family waits — even by a few weeks past the second anniversary — the case can be permanently barred, no matter how strong the proof.

We have seen Texas cases dismissed on the two-year SOL because a family thought the criminal case was the only case that mattered. The criminal case prosecutes the shooter. The civil case holds the motel accountable. They are two different fights, and the civil clock does not wait for the criminal one.

Tex. Civ. Prac. & Rem. Code § 16.003(b): “A person must bring suit for the death of an individual or for the injury of an individual not later than the second anniversary of the day the cause of action accrues.”

Texas Civil Practice and Remedies Code Chapter 125 — The Common-Nuisance Lever

Texas Civil Practice and Remedies Code Chapter 125 lets a city (or, in some circumstances, a private plaintiff) sue to abate a common nuisance. A “common nuisance” includes property that is “maintained or operated as a resort for prostitutes, habitual drunkards, or any person who habitually engages in the violation of the law” and, importantly, property used “in the commission of” certain habitual criminal acts. The City of Dallas has used Chapter 125 aggressively against chronic-nuisance motels, and it publishes a “habitual criminal property” registry under Dallas City Code provisions tying nuisance abatement to property owner accountability. If this motel is on that list, or should be, that fact becomes admissible and powerful in your civil case. It proves foreseeability, proves the operator had actual notice, and proves the city had already gone on record that the property was a danger to the public.

We do not wait for the city to file a Chapter 125 suit. We pull the city’s nuisance file, the police calls-for-service history, and the prior Chapter 125 actions against the same operator or any sister property.

What the Defense Will Argue — and How We Beat It

The motel will tell you four things, in roughly this order. Each of them is wrong in this case, and each has a Texas-law answer.

“It was a random drive-by. No one could have predicted it.” This is the Timberwalk answer. The five-factor test is the test. A parking lot that has had prior shootings, prior drug activity, prior police calls-for-service, prior “chronic-nuisance” designations, prior incident reports of suspicious vehicles or persons, prior written DPD advisories, and prior failed security audits is not a parking lot where a drive-by is “random.” The pattern makes the risk foreseeable; the failure to act on the pattern is the breach. The Texas pattern of cases involving motel and apartment-lot shootings overwhelmingly supports the family where the prior-incident record is well-developed.

“We had cameras. We had lights. We had locks.” Having cameras and lights is not the same as having a security program. Were the cameras pointed at the parking lot where the shooting happened, or at the front desk? Were they recording, or were they “placeholder” cameras that had not worked in months? Was the lighting measured to industry standards (typically IESNA recommendations), or was it a single dim bulb over the office? Did the motel have a written security-operations manual, a trained security director, and a documented incident-response protocol? Or did it have a sign that said “We have security” and nothing behind it? The defense will wave the word “security”; we will demand the records.

“The shooter is the bad guy, not us.” True, and we are pursuing the shooter too. The shooter is an intentional tortfeasor; the motel is a negligent one. The Texas Supreme Court in Timberwalk was explicit that the existence of a third-party criminal does not relieve the property owner of its own independent duty. The two wrongs do not cancel. A commercial property that knows criminal activity is happening on its land and does nothing is itself a wrongdoer — and under Texas proportionate-responsibility law, that wrongdoer takes a large share of the verdict.

“Comparative fault — the victim was in a high-crime area, knew it, and chose to be there.” This is the “assumption of risk” / “contributory negligence” play. Texas law on assumption of risk in premises cases has been narrowed substantially — the Texas Supreme Court in Cantu v. Horaney (2018) and subsequent decisions reined in the doctrine. The defense still tries it in motel parking-lot cases. The counter is concrete: a guest or visitor to a commercial premises has a right to assume reasonable security. The fact that the area has crime does not mean the visitor “assumed the risk” of being shot in a parking lot the operator should have made safe.

The defense playbook in this case is, in order:

1. The friendly phone call. Within 48–72 hours of the shooting, the motel’s insurance adjuster or a third-party administrator will call the family. The call will be warm, apologetic, and “just checking in.” The call is also a recorded statement trap. Anything the family says about the decedent’s habits, whereabouts, medical history, or the events of the day becomes discoverable and is routinely used to find a way to reduce the case. Do not give a recorded statement to the motel or its insurer without counsel present. We take the call; you do not.

2. The fast check with a release on the back. A “small token” settlement offer arrives in the first weeks. It is framed as “help with immediate expenses.” The release buried in the paperwork — the fine print the family doesn’t read — extinguishes the entire wrongful-death case, including the survival claim, in exchange for a few thousand dollars. Once signed, the case is over. Throw the offer in the trash and call us.

3. The social-media and surveillance sweep. Within days, the defense hires a private investigator to pull the decedent’s social media, run a background check, and canvass the parking lot for any “lurking” surveillance cameras from neighboring businesses. The point is not the evidence those sources hold — it is to find a way to characterize the decedent as someone who “lived a high-risk lifestyle” or was “involved in criminal activity.” It is also, often, the seed for a later “comparative fault” argument. We shut this down with a litigation-hold letter and a public-records request to the motel demanding its own CCTV.

4. The “you can’t prove foreseeability” motion. A traditional motion for summary judgment in a negligent-security case attacks the foreseeability element — the Timberwalk factors. We defeat it with the very records the defense hoped no one would request: the DPD calls-for-service history at the property, the prior incident reports, the brand-standards manual, the security-contractor log, the failed audit findings, the city’s nuisance file. The summary-judgment record in this kind of case is won or lost in the months before the motion is filed, in the records that were preserved — or not.

5. The “blame the victim” trial theme. At trial, expect the defense to argue the decedent was in the wrong place at the wrong time, that the shooting was gang-related, that the decedent had a prior record, that the visit to the motel was for an improper purpose. None of this is admissible in the first instance, and most of it is irrelevant to foreseeability. We pre-empt the trial theme with a motion in limine, with a careful jury selection, and with a client-prepared narrative that puts the focus where the law puts it: on what the motel knew and what the motel did not do.

The Damages — What Your Family Can Recover in Texas

Texas does not cap wrongful-death or general negligence damages. (Tex. Civ. Prac. & Rem. Code § 74.301’s cap applies to health care liability claims, not to negligent-security or wrongful-death claims against a commercial premises.) That matters — it means a Dallas motel that takes the bulk of the verdict is exposed for the full number the jury returns.

Under the Texas Wrongful Death Act, the surviving spouse, children, and parents may recover:

• Lost financial support — the income the decedent would have contributed to the family over the remainder of the decedent’s worklife, calculated by a forensic economist using the decedent’s age, education, earnings history, and life expectancy tables.
• Loss of services — the value of the household tasks the decedent performed (childcare, cooking, repairs, yard work, transportation) measured by their replacement cost on the open market.
• Loss of companionship and society — the spouse’s loss of the marital relationship; the parents’ loss of the child’s love, comfort, and guidance; the children’s loss of parental guidance. Texas law treats this as a real, recoverable head of loss even though no receipt is attached to it.
• Loss of inheritance — the net estate the decedent would have been expected to accumulate and leave to the family, calculated as the surplus of lifetime earnings over lifetime consumption.
• Mental anguish — the grief, sorrow, and emotional distress suffered by the survivors. Texas allows recovery for mental anguish in a wrongful-death case.
• Funeral and burial expenses — paid by the family or by the estate through the survival action.

Under the Texas Survival Statute, the estate may recover for the decedent’s own:

• Pre-death conscious pain and suffering — the physical pain and mental anguish the decedent experienced from the moment of being shot until death. This requires medical evidence of consciousness after the injury.
• Pre-death medical expenses — the cost of emergency care, surgery, ICU, and end-of-life care between the shooting and death.
• Lost earnings between injury and death — the income the decedent would have earned had he or she survived the work-life lost.

For the three survivors who were shot but lived, the recoverable damages are similar but personal: past and future medical bills, lost wages and earning capacity, physical pain and mental anguish, loss of enjoyment of life, and disfigurement. If any of them sustained a traumatic brain injury, the cost of a lifetime of care runs into the millions, and the law requires the at-fault party to pay it. ([Internal link: see our guide on brain injury lawsuits for how these claims are built and what they are worth.])

The PTSD layer. Shooting victims — and the families of those killed — are at very high risk for post-traumatic stress disorder, major depression, and the long-term sequelae of violent injury. The largest studies of trauma to date identify rape and violent assault as the single most psychologically damaging categories of trauma a person can experience. A PTSD diagnosis is real medical injury with eight formal criteria in the DSM-5; it is provable with validated instruments (CAPS-5, PCL-5), and it is fully compensable in Texas. ([Internal link: see our guide on PTSD payouts after a car accident — the same rules apply to assault and shooting PTSD.])

Realistic case-value range. Based on the case-value frame for negligent-security cases in major Texas metros — one death plus three injuries, with clear Timberwalk evidence and no comparative-fault reduction of more than 30% — the defensible range for settlement negotiation and jury trial is $1.5 million to $7.5 million or more, depending on:

• the age and earnings trajectory of the decedent;
• the strength of the prior-incident record at the motel;
• the comparative-fault percentage the jury is likely to assign;
• the severity of the survivors’ injuries (TBI, permanent orthopedic injury, PTSD);
• the availability and limits of insurance coverage (CGL + umbrella + excess).

We will not promise a number. We will tell you, after the records are in, what the case is realistically worth and what we will fight for. Past results depend on the facts of each case and do not guarantee future outcomes. We can tell you that negligent-security verdicts in Texas have repeatedly produced seven- and eight-figure results when the Timberwalk record is developed and the proof is preserved.

The First 72 Hours — What to Do and What to Refuse to Do

The first three days after a motel shooting in Dallas are when the case is won or lost. The decisions are simple, but they are unforgiving. The single biggest mistake families make is treating the civil case as the criminal case’s sequel, not as its own first-priority fight. The criminal case prosecutes the shooter. The civil case holds the motel accountable. They run on different clocks.

What to do, in order:

• Get medical care for the survivors, and document everything. For the deceased, ensure the medical examiner’s office and the funeral home have full records. For the survivors, every chart, scan, and treatment note is a piece of the damages proof.
• Preserve the scene. Photograph the parking lot, the lighting, the camera locations, the lot lines, the sightlines, and the property’s perimeter. Photograph at the same time of day as the shooting.
• Identify witnesses. Anyone who saw the shooting, anyone who lives or works nearby, anyone who can describe the motel’s reputation in the neighborhood, anyone who was a prior victim of crime at that property — every one of them is a witness. Get names and contact information today.
• Pull the police report number and the incident location. This is the key to the Texas Public Information Act requests that follow.
• Call us. 1-888-ATTY-911. We do the rest.

What to refuse to do:

• Do not give a recorded statement to the motel, the franchisor, or any insurance adjuster. Not without counsel present. They will be friendly. The call is recorded. The recording is used to find ways to reduce your family’s case.
• Do not sign anything — not a “sympathy check” release, not a “medical records authorization,” not a “privacy waiver,” not a “limited liability release” for the security contractor. Every piece of paper from the defense side contains a release. The token offer is the costliest paper you will ever sign.
• Do not post about the shooting on social media. The defense will pull it. Photos of the funeral, comments about the decedent’s habits, posts about how angry you are — every one of them will be quoted at deposition.
• Do not speak to the press without a plan. A well-meaning reporter can repeat something you said in a way that is harmful in a deposition six months from now. We help coordinate the family message.
• Do not assume the criminal case is your civil case. The Dallas County District Attorney’s office will prosecute the shooter. We will pursue the motel. Two separate fights, two separate teams, two separate clocks.

The Court’s Process — How the Case Moves, End to End

Knowing what comes next takes some of the fear out of the process. The timeline below is a typical Dallas County negligent-security case from intake to verdict. Every case is different; this is the architecture.

Days 1–14. Litigation-hold letters, public-records requests, witness identification, scene preservation, defendant identification, expert retention, demand package to the carrier. This is the most intense period of the case and the most important. What you do in the first two weeks determines what the case is worth for the rest of its life.

Months 1–6. Discovery — written requests for documents, written interrogatories, requests for admission, and depositions of the corporate representatives under Texas Rule of Civil Procedure 199.2(b). We depose the motel’s general manager, the regional or district manager, the security contractor’s account supervisor, the franchisor’s brand-standards director, the prior-incident witnesses, and the treating physicians.

Months 6–12. Expert reports. The security consultant, criminologist, forensic economist, and life-care planner complete their reports. The defense produces its own experts. Expert depositions follow.

Months 12–18. Dispositive motions. The defense typically files a motion for summary judgment attacking foreseeability under Timberwalk. The response is the Timberwalk record we have built from the very first day. The court hears oral argument and rules. If summary judgment is denied, the case proceeds to trial. If granted, we appeal.

Months 18–30. Trial. A Dallas County negligent-security case typically takes 3 to 5 days of trial. Jury selection in Dallas County is challenging; the venire is large and diverse. We work the panel to find jurors who understand that a commercial motel owes its visitors a real duty of care and that the Timberwalk factors are not abstractions.

Post-trial. Judgment, post-trial motions, appeal. The defendant’s insurance carrier may also pursue an interlocutory appeal of an adverse summary-judgment ruling under Texas Rule of Appellate Procedure 29.1 — this is common in negligent-security cases and is itself a leverage point.

Frequently Asked Questions

How long do I have to file a wrongful-death or personal-injury lawsuit in Texas after a motel shooting?

Two years from the date of death (for wrongful death) or the date of injury (for personal injury), under Tex. Civ. Prac. & Rem. Code § 16.003. Survival claims are also subject to the two-year deadline. The clock does not wait for the criminal case to resolve, and a government-entity claim (if any) under the Texas Tort Claims Act has a separate six-month presentment deadline under § 101.101. Do not wait. Call us at 1-888-ATTY-911 today.

Who can bring a wrongful-death claim under Texas law?

The surviving spouse, children, and parents of the decedent may bring a claim under the Texas Wrongful Death Act (Tex. Civ. Prac. & Rem. Code § 71.004). Brothers, sisters, grandparents, and friends are not statutory beneficiaries under the Texas statute (with limited exceptions for adopted children and stepchildren). The estate brings the separate survival claim for the decedent’s pre-death conscious pain and suffering.

What does the motel have to prove to avoid liability?

Under Timberwalk Apartments, Inc. v. Cain, 972 S.W.2d 749 (Tex. 1998), foreseeability is the linchpin. If the criminal act was foreseeable, the motel had a duty. The defense will try to show the shooting was random and unforeseeable. The Timberwalk five-factor test — proximity, recency, frequency, similarity, and publicity of prior crimes — is the standard the court uses to determine foreseeability, and it is the test on which the case will rise or fall.

What if my loved one was in a high-crime area of Dallas and “knew the risk”?

Texas law has narrowed the assumption-of-risk defense in premises cases following Cantu v. Horaney (2018) and its progeny. A guest or visitor to a commercial premises does not, by entering the parking lot of a paid motel, assume the risk of being shot. The defense will try comparative fault and assumption of risk; we will answer with the Texas pattern of cases and the Timberwalk foreseeability record.

How much is my case worth?

Case value depends on the strength of the liability case and the damages. The realistic case-value range for a Dallas motel negligent-security case involving one death and three injuries, with a developed Timberwalk record, is $1.5 million to $7.5 million or more. The exact number depends on the decedent’s earnings trajectory, the comparative-fault percentage, the severity of the survivors’ injuries, and the available insurance. We give you a real number once the records are in. Past results depend on the facts of each case and do not guarantee future outcomes.

Can we sue the motel brand — the national chain on the sign?

Often, yes. The deeper the franchisor’s brand standards reach into day-to-day security operations — camera coverage, lighting standards, security staffing, training, the security-operations manual, periodic inspection reports, mystery-shopper audits — the more likely a Texas court will allow the franchisor to be held responsible. We will obtain the franchise agreement and the brand-standards manual, and we will tell you honestly whether the franchisor belongs in the case.

What about the shooter — can we sue the shooter too?

Yes. The shooter is the intentional tortfeasor and a direct defendant in a wrongful-death case. In many cases, the shooter is judgment-proof — no insurance, no assets, incarcerated. We name the shooter anyway, because (a) it is the right thing to do, (b) it preserves the comparative-fault allocation on the verdict form, and (c) any future recovery from a third party (such as a bar that overserved the shooter, a gun seller, or a co-conspirator) is preserved.

Who pays the verdict — the motel owner or the insurance company?

In a commercial-premises case, the answer is almost always the insurance company, paid out under the motel’s commercial general liability (CGL) policy and any umbrella or excess coverage. Some CGL policies contain an assault-and-battery exclusion; many of those exclusions are litigated and many do not bar coverage for negligent security as opposed to the intentional act of the shooter. We do the coverage work as carefully as we do the liability work.

I have already given a recorded statement to the insurance adjuster. Have I destroyed my case?

Almost certainly not. Recorded statements can be a problem, but they are rarely fatal. Stop all further conversations immediately and call us. The earlier mistakes are corrected, the more manageable the case becomes.

What does it cost to hire you?

We work on contingency. No fee unless we win. The standard contingency fee is 33.33% before trial and 40% if the case goes through trial. We advance the costs. The free consultation is exactly that — free, confidential, and without obligation. You pay nothing up front. Hablamos Español — full consultations and complete case management in Spanish.

The motel wants to settle quickly. Should I take the offer?

Almost certainly not without counsel reviewing it. A quick settlement in the first weeks is designed to lock in a small number while the evidence is unpreserved and the family’s grief is freshest. Throw the offer in the trash and call us. We will tell you whether the offer reflects real value or a fraction of what the case is worth.

Will the case settle without going to trial?

Most negligent-security cases settle before trial, especially when the Timberwalk record is well-developed and the insurance carrier is looking at a Dallas County jury. A case that is built to be tried is a case that settles for the right number. We negotiate from the day the case is filed; we go to trial the day the offer is wrong.

I am not in Houston, Austin, or Beaumont. Can you still handle my case?

Yes. We take cases across Texas, and the firm’s statewide practice covers commercial-premises, catastrophic-injury, and wrongful-death cases. The Dallas motel shooting is the kind of case we handle anywhere in Texas. Call 1-888-ATTY-911 and we will talk about how to proceed.

What if my loved one didn’t die — what if they were only injured?

The two-year personal-injury statute of limitations still applies, and the same Timberwalk framework governs the motel liability question. The damages model is similar but personal: past and future medical, lost wages and earning capacity, physical pain, mental anguish, loss of enjoyment of life, disfigurement, and PTSD treatment. The case is no less serious. We pursue them with the same intensity.

Will I have to testify?

Almost certainly yes, at deposition and possibly at trial. We prepare you for every deposition personally. We do not put a client in a deposition or on a witness stand unprepared. The defense will try to rattle you. We make sure they cannot.

How long will the case take?

It depends on the injuries, the court, the defense, and the litigation path. A Dallas motel negligent-security case typically resolves in 18 to 36 months from filing, sometimes sooner on a strong record, sometimes longer if the defense fights through trial. We will give you a realistic timeline at intake.

The criminal case against the shooter is still pending. Should I wait for it to finish before starting the civil case?

No. The civil case is independent. It runs on its own clock, and the two-year statute of limitations will run regardless of what happens in the criminal courts. Moreover, the criminal case gives the defense free time to develop arguments, take statements, and lock in evidence. The civil case is the family’s case, and it should be started now.

Can I be forced into arbitration?

It depends on the registration paperwork signed at check-in. Many motels include an arbitration clause in the registration card or the mobile-app terms. The clause may or may not be enforceable against a third-party visitor (as opposed to the registered guest). We evaluate the arbitration question at intake. Even where arbitration applies, the substantive case does not disappear — it just moves into a private forum with different procedural rules.

What is the single most important thing I can do today?

Call us at 1-888-ATTY-911. Everything else — the evidence preservation, the public-records requests, the expert retention, the defendant identification — flows from that call. The motel will start its own defense within 24 to 48 hours of the shooting. The family needs to start its own case at the same time.

The Bottom Line

A drive-by shooting in a Dallas motel parking lot is a wrongful-death and personal-injury case against the motel that let it happen. The Texas Supreme Court’s Timberwalk decision, the Texas Wrongful Death Act, the Texas Survival Statute, Chapter 33’s proportionate-responsibility framework, the two-year statute of limitations, and the City of Dallas’s Chapter 125 common-nuisance authority all converge on the same question: did the motel do what a reasonable commercial property should have done, and did the failure to do it cause the death of your loved one? In a Dallas motel parking lot, with a known chronic-nuisance history, an inadequate security program, and a documented Timberwalk pattern, the answer is almost always yes.

We do not get paid unless you do. The free consultation is free. The case evaluation is confidential. Hablamos Español. The 24/7 hotline is staffed by people, not a service. The lawyers you meet at the first conference are the lawyers who try your case.

Call 1-888-ATTY-911 (1-888-288-9911). Right now. Before the CCTV overwrites. Before the adjuster’s friendly call. Before the family signs the token release that closes the case. Before another day of the motel’s lawyers building a defense against you.

The case is winnable. The case is worth pursuing. The case starts the day you decide it does.

Attorney911 — The Manginello Law Firm, PLLC — Legal Emergency Lawyers™ — Texas trial lawyers for the family the motel failed to keep safe.

Past results depend on the facts of each case and do not guarantee future outcomes.