Antonio Cortez v. Progressive County Mutual Insurance Company
Antonio Cortez appealed a summary judgment against him in an insurance discrimination case, alleging that Progressive County Mutual Insurance Co.'s variable commission program violated Texas Insurance Code article 21.21-8 by charging consumers of the same risk different rates based on agent commission levels. The trial court had granted summary judgment for Progressive, concluding that 'unfair discrimination' was defined by article 21.21-6 and that Cortez had not shown evidence of discrimination or economic damages. The appellate court reversed, holding that article 21.21-8 contains its own definition of unfair discrimination, distinct from article 21.21-6, and that Cortez had presented more than a scintilla of probative evidence to create a genuine issue of material fact regarding unfair discrimination and economic damages. The case was remanded for further proceedings.