Philadelphia Indemnity Insurance Company, A/S/O Mirsan, L.P., D/B/A Sienna Ridge Apartments v. Carmen A. White
This dissenting opinion by Justice Boyd, joined by Justices Willett, Lehrmann, and Devine, disputes the majority's allocation of the burden of proof in a case involving fire damage to a tenant's apartment. The central issue is whether the tenant, Carmen White, or the landlord/insurer, Philadelphia Indemnity Insurance Company, bears the burden of proving the cause of the fire under the Texas Property Code. The dissent argues that the landlord has an unwaivable duty to repair unless the tenant caused the damage, and the burden to prove this exception (that the tenant caused the fire) rests with the landlord. The dissent contends that the lease provision requiring the tenant to pay for damages not caused by the landlord's negligence is unenforceable under the Property Code, which prohibits landlords from avoiding their duty to repair conditions affecting health and safety unless the tenant caused them. Since the landlord failed to secure a jury finding that White caused the fire, the dissent believes the court of appeals' decision, which favored the tenant, should have been affirmed.