In most cases, the duty is to use reasonable care. In the Kitchen case, a driver in a pickup truck hit a patch of ice on a bridge and skidded out of control, colliding with an oncoming truck. Kitchen,.By: Nick Christopherson. Travis Scott's recent Astroworld music festival drew an estimated 50,000 fans to NRG Park in Houston on Friday, November 5. There are three types of tort actions; negligence, intentional torts, and strict liability. The elements of each are slightly different. The lawsuits, 46 and counting as of Wednesday, accuse Scott, Live Nation and others involved in operating Astroworld of being legally negligent. In our prior cases, we have stated that when a supervisor engages in tortious conduct such as sexual or other types of harassment, the supervisor=s. We would hold that plaintiff Travis has presented facts insufficient to establish an intentional tort. While her employer was negligent and even reckless.