Universe Life Insurance v. Giles
Justice Hecht's concurring opinion addresses the complex issues surrounding insurance bad-faith liability in Texas. He critiques the existing 'no reasonable basis' standard for its difficulty in appellate review, particularly due to the limitations of no-evidence review which prevents weighing conflicting evidence. He advocates for defining bad faith as 'unscrupulous, arbitrary conduct' and for treating the 'reasonably clear' liability standard as a legal question rather than a factual one. This approach, he argues, would provide clearer guidelines for insurers and enable meaningful judicial review, preventing juries from arbitrarily defining bad faith. Furthermore, he emphasizes that the requisite mental state for bad-faith liability should involve intentional or reckless conduct, not mere negligence. He concurs with the judgment that Universe Life wrongfully delayed Giles' claim (thus implying the claim for benefits was granted) but finds no evidence for punitive damages.