Texas Mutual Insurance Co. v. Sara Care Child Care Center, Inc.
Texas Mutual Insurance Company appealed two summary judgment orders and a final judgment in favor of its insured, Sara Care Child Care Center, Inc., and employee Martha Martinez. The core issue was whether Sara Care's workers' compensation policy was extended due to Texas Mutual's alleged failure to comply with statutory cancellation notice requirements, thus covering Ms. Martinez's injury. The Workers' Compensation Commission Appeals Panel and the trial court affirmed coverage. The appellate court affirmed the trial court's judgment regarding judicial review of the Appeals Panel decision, Sara Care's common law claims (breach of contract, promissory estoppel), and the attorney's fee award. However, the court reversed and remanded the trial court's judgment on Sara Care's statutory claims (Texas Insurance Code and Texas Deceptive Trade Practices Act) and the 'knowingly' finding, stating a fact issue remained on whether coverage liability was 'reasonably clear' for these claims.