Case No. MISSINGRegular Panel Decision American Risk Funding Insurance Co. Ex Rel. Continental Casualty Co. v. Lambert
This case involves an appeal from a summary judgment concerning a workers' compensation carrier's waiver of subrogation rights. Larry Lambert, Rogers Patino, and Andres Garcia (appellees), employees of U.S. Contractors, Inc., were injured in a chemical plant explosion and settled with third-party defendants (Memc Pasadena, Inc., J.E. Merit Contractors, Inc., and Albemarle Corporation) for $1.8 million. American Risk Funding Insurance Company (appellant), the workers' compensation carrier for U.S. Contractors, Inc., intervened to seek reimbursement for benefits paid, but Lambert denied the claim due to a prior contract waiving subrogation rights. The trial court granted Lambert's motion for summary judgment, which American Risk Funding appealed. The appellate court addressed five issues raised by the appellant, primarily concerning the validity and scope of the subrogation waiver, including arguments about public policy, lack of consideration, intent to benefit appellees, waiver of future benefits, and common law conversion. The court systematically overruled all of appellant's issues, concluding that the waiver of subrogation does not violate public policy, does not require separate consideration, was intended to apply as contracted, waives rights to future credits, and extinguishes common law claims related to subrogation. Consequently, the judgment of the trial court affirming the summary judgment in favor of Lambert was affirmed.
Workers' CompensationSubrogation WaiverSummary Judgment AppealPublic PolicyContract LawTexas LawInsurance Carrier RightsEmployee RightsThird-Party LiabilityReimbursement