Texas City Patrol, LLC v. El Dorado Insurance Agency, Inc.
Texas City Patrol, LLC appealed the trial court's dismissal of its claims against El Dorado Insurance Agency, Inc. The case originated when Texas City Patrol, a security company, obtained a commercial automobile insurance policy through El Dorado, and a company employee was later injured in an accident. The insurer, Progressive, initially denied an uninsured motorist claim, leading Texas City Patrol to allege misrepresentation by El Dorado regarding coverage. Texas City Patrol subsequently sued El Dorado, alleging violations of the Texas Insurance Code, DTPA, breach of contract, and breach of the duty of good faith and fair dealing. The trial court granted El Dorado's motion to dismiss and awarded attorney's fees. The appellate court affirmed the trial court's decision, concluding that El Dorado, as an insurance agent and not the insurer, was not liable under the various statutes and common law duties invoked by Texas City Patrol.