CompFox Logo
AboutWorkflowFeaturesPricingCase LawInsights

Updated Daily

Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 19-0791, 19-0792
Regular Panel Decision
Mar 19, 2021

in Re State Farm Mutual Automobile Insurance Company and Todd Joseph Dauper

This case from the Supreme Court of Texas consolidates two petitions for writ of mandamus concerning underinsured motorist (UIM) insurance claims. Relators State Farm Mutual Automobile Insurance Company, Terecina Shahan, and Todd Joseph Dauper sought to overturn trial court denials of their motions for bifurcated trials. The underlying suits, brought by real parties in interest Al Dodds and Alexander Nicastro, alleged only extracontractual violations of the Texas Insurance Code, seeking UIM benefits as damages, but did not include breach-of-contract claims. State Farm argued that an insured must first establish legal entitlement to policy benefits by proving the underinsured motorist's liability and damages in an initial "car crash" trial, even if only statutory claims are pleaded. The Court agreed, holding that such a showing is a prerequisite for recovering on Insurance Code claims when damages are predicated on policy benefits. It found that denying bifurcation was an abuse of discretion, citing the need to preserve judicial resources and prevent prejudice from the admission of settlement offers. The Court conditionally granted the petitions, directing the trial courts to bifurcate the trials.

Underinsured Motorist InsuranceInsurance Code ClaimsBifurcation of TrialsWrit of MandamusExtracontractual ClaimsPolicy BenefitsTexas Civil ProcedureJudicial DiscretionTrial AbatementSettlement Offers
References
34
Case No. 02-17-00276-CV
Regular Panel Decision
Nov 15, 2018

William Blevins v. State Farm Mutual Automobile Insurance Company

William Blevins appealed an unfavorable jury verdict in his declaratory-judgment action against State Farm Mutual Automobile Insurance Company for underinsured-motorist benefits, after settling with the two drivers involved in his accident. Blevins's primary claim was for a permanent traumatic brain injury resulting in diminished cognitive abilities, seeking at least $300,000 in damages. The jury, however, awarded zero damages for past and future physical pain, mental anguish, disfigurement, and physical impairment. The Court of Appeals affirmed the trial court's judgment, concluding that the jury's findings of zero damages were not against the great weight and preponderance of the evidence, particularly given the strong impeachment of Blevins's expert and the largely subjective nature of the alleged traumatic brain injury. The court also found no abuse of discretion in quashing a trial subpoena for a State Farm representative or in the jury instructions.

Underinsured Motorist BenefitsJury Verdict AppealZero Damages AwardEvidentiary SufficiencyTraumatic Brain Injury ClaimCognitive DeficitsExpert Witness ImpeachmentNon-economic DamagesPhysical Pain and Mental AnguishDisfigurement and Impairment
References
33
Case No. 14-04-00357-CV
Regular Panel Decision
Jan 26, 2006

Bruce and Vonnie Lundstrom v. United Services Automobile Association - CIC

This case concerns a homeowners insurance coverage dispute between the Lundstroms (insureds) and United Services Automobile Association-CIC (USAA), the insurer. The Lundstroms appealed a summary judgment granted in favor of USAA regarding the denial of coverage under their Homeowners Form B policy after water damage and subsequent mold growth in their townhome. The appellate court affirmed the summary judgment, concluding that USAA's defenses to contractual and bad faith claims were established, and the Lundstroms failed to provide evidence for their claim under former Insurance Code Article 21.55. The court determined that mold damage was excluded from coverage and the initial water damage was resolved by binding appraisal.

Homeowners InsuranceInsurance Policy CoverageSummary Judgment AppealWater Damage ClaimsMold Exclusion ClauseBad Faith Insurance PracticesDeceptive Trade Practices Act (DTPA)Texas Insurance Code Article 21.55Appraisal AwardContractual Claims
References
49
Case No. MISSING
Regular Panel Decision

Laurence v. State Farm Mutual Automobile Insurance Co.

Appellant Jeane Laurence sustained $14,325.23 in damages from a hit-and-run accident. Her State Farm automobile policy included both Uninsured Motorist (UM) and Personal Injury Protection (PIP) coverages, with limits of $50,000 and $5,000 respectively. After receiving $4,325.23 in PIP benefits, Laurence sought full UM benefits. State Farm invoked a policy provision to offset the PIP payments from the UM benefits to prevent recovery exceeding actual damages. The trial court upheld this PIP offset provision, reducing Laurence's UM payout. The appellate court affirmed the trial court's decision, concluding that the offset clause was valid under Texas law and public policy, as the insured's actual damages were less than the combined available coverages, thereby preventing an unintended double recovery.

Uninsured Motorist CoveragePersonal Injury Protection (PIP)Insurance Policy OffsetAutomobile InsuranceSummary JudgmentDouble RecoveryStatutory InterpretationCollateral Source RuleAppellate ReviewActual Damages
References
29
Case No. MISSING
Regular Panel Decision

Kim v. State Farm Mutual Automobile Insurance Co.

Tammy Kim appealed a summary judgment granted in favor of State Farm Mutual Automobile Insurance Company. Kim was injured in an accident involving an uninsured motorist and sought benefits under her parents' State Farm policy, which included PIP and UM coverage. State Farm paid $2500 in PIP benefits and $7500 in UM benefits, offsetting the PIP amount from the total stipulated damages of $10,000. Kim argued that the offset was improper, contending she was entitled to $10,000 in UM benefits in addition to the PIP payments. The appellate court affirmed the trial court's decision, finding that the insurance policy's clear language permitted State Farm to offset PIP payments against UM benefits to avoid paying more than the actual damages sustained.

Summary Judgment AppealInsurance Policy InterpretationUninsured Motorist CoverageUnderinsured Motorist CoveragePersonal Injury ProtectionPIP OffsetUM BenefitsContract LawTexas Insurance CodeAutomobile Accident
References
13
Case No. 03-97-00448-CV
Regular Panel Decision
Jan 14, 1999

Jeane Laurence v. State Farm Mutual Automobile Insurance Company

This appeal examines the validity of an automobile insurance policy provision. The provision allows for the reduction of uninsured motorist (UM) benefits by the amount of personal injury protection (PIP) benefits already paid to the insured. Appellant Jeane Laurence argued that this offset provision was invalid and unenforceable under Texas law and public policy, challenging the trial court's summary judgment in favor of appellee State Farm Mutual Automobile Insurance Company. The appellate court analyzed relevant Texas Insurance Code statutes and prior case law concerning UM and PIP coverages, particularly regarding the prevention of double recovery. The court ultimately affirmed the trial court's decision, concluding that the offset clause was valid when the insured's actual damages were less than the combined PIP and UM coverages.

Automobile InsuranceUninsured Motorist CoveragePersonal Injury ProtectionPIP OffsetInsurance Policy ValiditySummary JudgmentCollateral Source RuleDouble RecoveryStatutory InterpretationTexas Insurance Law
References
19
Case No. 14-03-00164-CV
Regular Panel Decision
Mar 31, 2005

Christine H. De Laurentis v. United Services Automobile Association A/K/A USAA

This case addresses an insurance-coverage dispute between policyholder Christine H. de Laurentis and insurer United Services Automobile Association (USAA) over mold damage in her apartment, allegedly caused by a leaking air conditioning unit. The trial court initially granted summary judgment for USAA, dismissing all claims. On appeal, the court reversed the summary judgment regarding the breach-of-contract claim, holding that mold damage caused by a leaking air conditioning unit could be covered as a 'physical loss' under the named-perils policy, and found that USAA had waived the inventory requirement. However, the court affirmed the dismissal of the extracontractual claims.

Insurance CoverageMold DamageRenter's Insurance PolicyAir Conditioning LeakBreach of ContractExtracontractual ClaimsSummary JudgmentCondition Precedent WaiverNamed Perils PolicyPhysical Loss
References
25
Case No. MISSING
Regular Panel Decision
Jun 14, 1963

International Union, United Automobile, Aircraft & Agricultural Implement Workers v. American Metal Products Co.

The case involved American Metal Products Company (Ampco) suing two labor unions, Local 1198 UAW and International Union UAW, for damages resulting from a violent strike in Obion County, Tennessee. The unions' conduct included harassment, mass picketing, intimidation, and violence, leading to significant disruption of Ampco's business operations. The Circuit Court initially awarded Ampco compensatory and punitive damages. On appeal, the court affirmed the unions' liability for tortious conduct, emphasizing the state's interest in maintaining public order. However, the appellate court reduced the compensatory damages by limiting the compensable period, resulting in a final judgment of $64,737.59 against the unions, including $50,000 in punitive damages.

Labor RelationsUnion StrikeIndustrial ActionTort LawPunitive DamagesCompensatory DamagesFederal PreemptionLabor Management Relations Act (LMRA)PicketingViolence
References
30
Case No. MISSING
Regular Panel Decision

West v. Pratt

This appeal addresses the allocation of compensatory and punitive damages between a liability insurer and an uninsured motorist carrier in Tennessee. State Farm Mutual Automobile Insurance Company, the uninsured motorist carrier for plaintiffs Glenn and Shari West, challenged Tennessee Farmers Mutual Insurance Company's, the liability insurer for defendant Horace Pratt, decision to apportion its policy limits between compensatory and punitive damages. State Farm argued this allocation improperly shifted responsibility for punitive damages to them, a result prohibited by Tennessee public policy concerning uninsured motorist coverage. The Tennessee Supreme Court reversed the lower courts' rulings, holding that a liability carrier must first satisfy compensatory damage awards to the extent of its limits before applying any funds to punitive damages, unless the policy explicitly states otherwise. This decision underscores the state's public policy against indirectly burdening uninsured motorist carriers with punitive damage obligations.

Allocation of damagesPunitive damagesCompensatory damagesUninsured motorist coverageUnderinsured motorist coverageLiability insuranceInsurance policy limitsPublic policyTennessee lawStatutory interpretation
References
7
Case No. MISSING
Regular Panel Decision

De Laurentis v. United Services Automobile Ass'n

This case concerns an insurance-coverage dispute between Christine H. de Laurentis (Policyholder) and United Services Automobile Association (Insurer) regarding mold damage to her apartment. The Policyholder claimed the mold resulted from a leaking air conditioning unit, but the Insurer denied coverage under her renter's insurance policy (HOB-T), stating mold was not a named peril. The trial court initially granted summary judgment for the Insurer on all claims. On appeal, the court overruled the Policyholder's motion for rehearing. It reversed and remanded the breach-of-contract claim, concluding the Insurer waived an inventory requirement and that the policy's 'physical loss caused by a peril' language could cover mold damage from a water leak. However, the dismissal of the extracontractual claims was affirmed.

Insurance DisputeMold DamageRenter's InsuranceHOB-T PolicyBreach of ContractExtracontractual ClaimsSummary JudgmentWaiver of Condition PrecedentPolicy InterpretationCausation
References
24
Showing 1-10 of 4,486 results

Ready to streamline your practice?

Apply these legal strategies instantly. CompFox helps you find decisions, analyze reports, and draft pleadings in minutes.

CompFox Logo

The AI standard for workers' compensation professionals. Faster research, deeper analysis, better outcomes.

Product

  • Platform
  • Workflow
  • Features
  • Pricing

Solutions

  • Defense Firms
  • Applicants' Attorneys
  • Insurance carriers
  • Medical Providers

Company

  • About
  • Insights
  • Case Law

Legal

  • Privacy
  • Terms
  • Trust
  • Cookies
  • Subscription

© 2026 CompFox Inc. All rights reserved.

Systems Operational