Travelers Indemnity Co. of Rhode Island v. Starkey
The Travelers Indemnity Company of Rhode Island appealed a trial court's judgment that awarded death benefits to Lynn Edward Starkey and Hazel Dean Starkey under the Texas Workers’ Compensation Act. The case stemmed from Jonathan Starkey's work-related injuries in 1984, for which Travelers paid indemnity benefits until his death in 2001. His parents subsequently sought death benefits, which Travelers disputed, asserting a right to deduct previously paid benefits. The trial court found that Travelers had waived this credit in a third-party settlement agreement. The appellate court affirmed, concluding that the contractual language constituted a waiver of Travelers' rights to an offset and upheld the award of benefits, attorneys' fees, interest, and costs to the Starkeys.