American National Insurance Company, and American National Property and Casualty Company v. Frank E. Cannon, II, Clifton Mark Grayless, Deborah Glenn, and Robert Westover, Individually and on Behalf of All Other Similarly Situated
This is an interlocutory appeal from a class certification order. American National Insurance Company (ANICO) and American National Property and Casualty Company (ANPAC) appealed the certification of a class action brought by former agents (Frank E. Cannon II, Clifton Mark Grayless, Deborah Glenn, and Robert Westover). The agents alleged breach of contract, fraud, negligent misrepresentation, and violations of the Deceptive Trade Practices Act and Insurance Code, seeking declaratory judgments regarding non-compete provisions and repayment of advance agreements. The appellate court found that individual issues, such as the reasonableness of non-compete restrictions and reliance on oral representations for advance payments, predominated over common issues. Consequently, the court determined that the requirements for class certification under Texas Rule of Civil Procedure 42(b)(4), (b)(2), and (b)(1)(A) were not satisfied. The class certification order was vacated, and the case was remanded to the trial court for further proceedings consistent with the opinion.