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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. 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. MISSING
Regular Panel Decision

State Farm Mutual Automobile Insurance v. Aetna Casualty & Surety Co.

This case concerns a dispute between insurance carriers following a workers' compensation claim. Douglas K. Ellsmore was injured while unloading a hospital bed when Shirley S. Miller, insured by State Farm Mutual Automobile Insurance Company, backed her car into him. Ellsmore's employer's workers' compensation carrier, Aetna Casualty and Surety Company, paid over $65,000 in benefits and then sought reimbursement from State Farm via a loss transfer claim and demanded arbitration under Insurance Law § 5105. State Farm initiated a special proceeding to permanently stay arbitration, arguing that Aetna's claim lacked legal basis. Special Term denied the stay, but the appellate court reversed this decision. The court clarified that the "for hire" provision in Insurance Law § 5105 modifies "vehicle," limiting its application to vehicles hired for transporting people (like taxis) or livery vehicles for property, and does not extend to commercial deliveries by an owner's vehicle. Consequently, Aetna was not entitled to recover compensation payments under this statute.

Insurance LawWorkers' CompensationAutomobile InsuranceLoss Transfer ClaimArbitration StayStatutory Interpretation"For Hire" ClauseCommercial DeliveryVehicle InsuranceFirst-Party Payments
References
1
Case No. 13-99-814-CV
Regular Panel Decision
Feb 01, 2001

State Farm Mutual Automobile Insurance Co. v. Lopez, Alicia

This is an interlocutory appeal challenging a trial court's order certifying a class action. The appellees, Alicia Lopez, Adan Munoz, Jr., Juan Llanes, Diana Moreno, and Albert Alaniz, sued their automobile insurance carriers, State Farm Mutual Automobile Insurance Company, alleging wrongful failure to pay adequate dividends to policyholders despite significant corporate surpluses, breach of contract, and fraud. Appellants, State Farm and Wendy L. Gramm, contested the class certification on grounds of lack of jurisdiction, absence of a viable cause of action (challenging typicality), and antagonistic interests among class members (challenging adequate representation). The Court of Appeals affirmed the trial court's class certification order, ruling that the trial court had jurisdiction and did not abuse its discretion in finding that the class met the typicality and adequate representation requirements.

Class ActionInterlocutory AppealInsurance LawDividendsPolicyholdersJurisdictionTypicalityAdequate RepresentationAbuse of DiscretionTexas Law
References
37
Case No. 01-19-00821-CV
Regular Panel Decision
Mar 17, 2020

in Re State Farm Mutual Automobile Insurance Company

State Farm Mutual Automobile Insurance Company, the relator, sought mandamus relief after the trial court refused to abate extra-contractual claims filed by Amanda Marie Sanchez Garza, the real party in interest. Garza had sued State Farm for uninsured/underinsured motorist (UIM) benefits, a declaratory judgment, breach of the duty of good faith and fair dealing, and violations of the Texas Insurance Code and the Texas Deceptive Trade Practices-Consumer Protection Act (DTPA). While the trial court severed the extra-contractual claims, it denied State Farm's motion to abate them. The Court of Appeals for the First District of Texas determined that extra-contractual claims in UIM cases are predicated on the insured's entitlement to UIM benefits, which had not yet been established. Thus, litigating these claims prematurely would cause undue burden and expense to State Farm. The court conditionally granted the petition for writ of mandamus, directing the trial court to abate the extra-contractual claims until the declaratory action is resolved.

MandamusAbatementExtra-contractual ClaimsUninsured/Underinsured MotoristUIM BenefitsInsurance LawTexas LawAppellate ReviewAbuse of DiscretionDeclaratory Relief
References
27
Case No. MISSING
Regular Panel Decision

State Farm Mutual Automobile Insurance v. Rabiner

State Farm Mutual Automobile Insurance Company (Plaintiff) sued Eric Hagerbrant and other defendants, including Metropolitan Radiological Imaging, P.C., to recover over $2,000,000 in alleged fraudulent no-fault insurance payments. Plaintiff asserted claims for common law fraud, unjust enrichment, and sought a declaratory judgment, alleging that Metropolitan was fraudulently incorporated and ineligible for payments. Defendants moved to dismiss the action, arguing preemption by New York Insurance Law § 5109, disputing the eligibility of independent contractors for No-Fault benefits, and asserting a statute of limitations defense. The court denied the defendants' motion in its entirety, finding that § 5109 did not eliminate a private right of action, the Insurance Department's position on independent contractors was valid, and the statute of limitations argument was premature.

Fraudulent IncorporationNo-Fault InsuranceUnjust EnrichmentDeclaratory Judgment ActionMotion to DismissPrivate Right of ActionInsurance Law InterpretationMedical Professional CorporationsIndependent Contractors EligibilityStatute of Limitations Defense
References
40
Case No. MISSING
Regular Panel Decision

State Farm Mutual Automobile Insurance Co. v. Brown

In this car insurance coverage case, State Farm Mutual Automobile Insurance Company appealed a summary judgment in favor of the insured, Jack Brown. The central issue was whether State Farm could offset payments made under the Personal Injury Protection (PIP) clause against payments owed under the Uninsured/Underinsured (UM) motorist clause, according to a policy offset provision. The trial court had concluded that State Farm was not entitled to such an offset. The appellate court examined the policy's offset clause, its validity, and various arguments raised by Brown, including claims of double recovery and statutory interpretation. Concluding that the offset is permissible and the clause valid, the court reversed the trial court's summary judgment for Brown and rendered judgment in favor of State Farm.

Car InsuranceUninsured Motorist CoverageUnderinsured Motorist CoveragePersonal Injury Protection (PIP)Offset ProvisionSummary JudgmentPolicy InterpretationTexas Insurance CodeSubrogationCollateral Source Rule
References
16
Case No. 03-02-00747-CV
Regular Panel Decision
Nov 06, 2003

United Services Automobile Association and USAA Life Insurance Company v. Carole Keeton Strayhorn, Comptroller of Public Accounts of the State of Texas, and Greg Abbott, Attorney General of the State of Texas

This appeal concerns a tax refund sought by United Services Automobile Association (USAA) for sales and use taxes paid between 1994 and 1999. USAA argued that repealed sections of the Texas Insurance Code (former articles 4.10 and 4.11) contained "no other tax" language, which they interpreted as exempting them from all state taxes not expressly provided for in the insurance code at that time. The district court denied USAA's claim and granted the Comptroller's motion for summary judgment, ruling that the insurance code provisions did not exempt USAA from sales and use taxes. The Court of Appeals, reviewing statutory interpretation and legislative history, determined that the tax exemption in the insurance code was narrowly intended to replace occupational and franchise taxes existing in 1907 when the law was first enacted, and did not apply to sales and use taxes, which were created much later in 1961. The court concluded that the exemptions were specific to a system of occupation taxes and did not cover general applicability taxes like sales and use taxes, thus affirming the district court's judgment.

Tax RefundSales TaxUse TaxInsurance CodeStatutory InterpretationLegislative IntentGross Receipts TaxOccupation TaxFranchise TaxTax Exemption
References
41
Case No. MISSING
Regular Panel Decision

State Farm Mutual Automobile Insurance Companies v. Brooks

This action arises from an alleged overpayment of no-fault benefits by State Farm to James Brooks. Brooks, injured in an automobile accident, received lost earnings benefits from State Farm, but was later furloughed from his job due to lack of work, not his injury, yet continued to receive full benefits. State Farm sought to recover the alleged overpayment, arguing an insurance regulation (11 NYCRR 65.6 (n) (2) (vi)) required a reduction to unemployment benefits if the position would have been lost regardless of the accident. The court, in a case of first impression, found this regulation invalid as applied to Brooks, conflicting with the Insurance Law's purpose of compensating for actual economic loss. Consequently, summary judgment was granted in favor of the defendant, James Brooks.

No-fault insuranceAutomobile accidentOverpayment of benefitsLost earningsUnemployment benefitsInsurance Law interpretationSummary judgmentStatutory conflictRegulation validityEconomic loss
References
13
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
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