coverage claim (Texas) · Go Syfert
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coverage claim in Texas

24 Texas opinions name it 3 courts 1940–2025 3 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
In Re Republic Lloydsgreen
texapp · 2003 · cited in 6 Texas opinions naming this issue, 2012–2012
2 sentences

2012See Akin, 927 S.W.2d at 630 (“In the absence of a settlement offer on the entire contract claim, or other compelling circumstances, severance is not required.”) [Emphasis added]; In re Republic Lloyds, 104 S.W.3d 354, 358 (Tex. App.-Houston [14th Dist.] 2003, orig. proceeding) (“Thus, pursuant to Akin , a severance is required when the insurer has made a settlement offer on the entire *236 breach of contract claim.”) [Emphasis added].

2012See Akin , 927 S.W.2d at 630 (“In the absence of a settlement offer on the entire contract claim , or other compelling circumstances, severance is not required.”)[Emphasis added]; In re Republic Lloyds , 104 S.W.3d 354, 358 (Tex.App.--Houston [14th Dist.] 2003, orig. proceeding)(“Thus, pursuant to Akin , a severance is required when the insurer has made a settlement offer on the entire breach of contract claim .”) [Emphasis added].

66
Liberty National Fire Insurance Co. v. Akingreen
tex · 1996 · cited in 6 Texas opinions naming this issue, 2012–2012
2 sentences

2012See Akin, 927 S.W.2d at 630 (“In the absence of a settlement offer on the entire contract claim, or other compelling circumstances, severance is not required.”) [Emphasis added]; In re Republic Lloyds, 104 S.W.3d 354, 358 (Tex. App.-Houston [14th Dist.] 2003, orig. proceeding) (“Thus, pursuant to Akin , a severance is required when the insurer has made a settlement offer on the entire *236 breach of contract claim.”) [Emphasis added].

2012See Akin , 927 S.W.2d at 630 (“In the absence of a settlement offer on the entire contract claim , or other compelling circumstances, severance is not required.”)[Emphasis added]; In re Republic Lloyds , 104 S.W.3d 354, 358 (Tex.App.--Houston [14th Dist.] 2003, orig. proceeding)(“Thus, pursuant to Akin , a severance is required when the insurer has made a settlement offer on the entire breach of contract claim .”) [Emphasis added].

66
Lamar Homes, Inc. v. Mid-Continent Casualty Co.green
tex · 2007 · cited in 3 Texas opinions naming this issue, 2008–2025
2 sentences

2025Lamar Homes Inc. v. Mid-Continent Cas., 242 S.W.3d 1, 8 (Tex. 2007).

2008We express no opinion on whether the coverage rule for determining if a claim occurs during the term of the OneBeacon policy is the same for bodily injury and property damage claims. 33 . 242 S.W.3d 1, 5 (Tex.2007). 34 .

23
Stroburg v. Insurance Company of North Americagreen
tex · 1971 · cited in 2 Texas opinions naming this issue, 1982–2000
2 sentences

2000“Independent” as used in the coverage clause means “solely,” “only,” and “standing alone.” Stroburg, 464 S.W.2d at 829 .

2000See id.

22
Wachovia Bank, National Ass'n v. Schmidtgreen
scotus · 2006 · cited in 1 Texas opinions naming this issue, 2024–2024
2 sentences

2024See Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 118-19 (2001) (construing FAA exclusion narrowly despite broad interpretation of comparable language in FAA’s coverage provision). “[I]dentical language may convey varying content when used in different statutes, sometimes even in different provisions of the same statute.” Yates v. United States, 574 U.S. 528 , 537, 135 S. Ct. 1074, 1082 , 191 L.Ed.2d 64 (2015) (plurality opinion).10 10 See, e.g., Wachovia Bank, N.A. v. Schmidt, 546 U.S. 303, 313-14 , 126 S. Ct. 941 , 163 L.Ed.2d 797 (2006) (“located” has different meanings in different pro

2024See Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 118-19 (2001) (construing FAA exclusion narrowly despite broad interpretation of comparable language in FAA’s coverage provision). “[I]dentical language may convey varying content when used in different statutes, sometimes even in different provisions of the same statute.” Yates v. United States, 574 U.S. 528 , 537, 135 S. Ct. 1074, 1082 , 191 L.Ed.2d 64 (2015) (plurality opinion).10 10 See, e.g., Wachovia Bank, N.A. v. Schmidt, 546 U.S. 303, 313-14 , 126 S. Ct. 941 , 163 L.Ed.2d 797 (2006) (“located” has different meanings in different pro

11
Circuit City Stores, Inc. v. Adamsgreen
scotus · 2001 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 118-19 (2001) (construing FAA exclusion narrowly despite broad interpretation of comparable language in FAA’s coverage provision). “[I]dentical language may convey varying content when used in different statutes, sometimes even in different provisions of the same statute.” Yates v. United States, 574 U.S. 528 , 537, 135 S. Ct. 1074, 1082 , 191 L.Ed.2d 64 (2015) (plurality opinion).10 10 See, e.g., Wachovia Bank, N.A. v. Schmidt, 546 U.S. 303, 313-14 , 126 S. Ct. 941 , 163 L.Ed.2d 797 (2006) (“located” has different meanings in different pro

11
Yates v. United Statesgreen
scotus · 2015 · cited in 1 Texas opinions naming this issue, 2024–2024
2 sentences

2024See Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 118-19 (2001) (construing FAA exclusion narrowly despite broad interpretation of comparable language in FAA’s coverage provision). “[I]dentical language may convey varying content when used in different statutes, sometimes even in different provisions of the same statute.” Yates v. United States, 574 U.S. 528 , 537, 135 S. Ct. 1074, 1082 , 191 L.Ed.2d 64 (2015) (plurality opinion).10 10 See, e.g., Wachovia Bank, N.A. v. Schmidt, 546 U.S. 303, 313-14 , 126 S. Ct. 941 , 163 L.Ed.2d 797 (2006) (“located” has different meanings in different pro

2024See Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 118-19 (2001) (construing FAA exclusion narrowly despite broad interpretation of comparable language in FAA’s coverage provision). “[I]dentical language may convey varying content when used in different statutes, sometimes even in different provisions of the same statute.” Yates v. United States, 574 U.S. 528 , 537, 135 S. Ct. 1074, 1082 , 191 L.Ed.2d 64 (2015) (plurality opinion).10 10 See, e.g., Wachovia Bank, N.A. v. Schmidt, 546 U.S. 303, 313-14 , 126 S. Ct. 941 , 163 L.Ed.2d 797 (2006) (“located” has different meanings in different pro

11
Mid-Century Insurance Co. of Texas v. Lindseygreen
tex · 1999 · cited in 1 Texas opinions naming this issue, 2005–2005
2 sentences

2005The Brown court applied the coverage test from Mid-Century Insurance Co. of Texas v. Lindsey, 997 S.W.2d 153, 157 (Tex.1999); that test, although not absolute, provides that, for coverage to exist under the policy language quoted above, (1) the accident must have arisen out of the inherent nature of the automobile, as such; (2) the accident must have arisen within the automobile’s territorial limits, and the actual use must not have terminated; and (3) the automobile must not merely contribute to cause the condition producing the injury, but must instead itself produce the injury.

2005Brown, 123 S.W.3d at 622 -23 (citing Lindsey, 997 S.W.2d at 157 ).

11
Garvey v. State Farm Fire & Casualty Co.green
cal · 1989 · cited in 1 Texas opinions naming this issue, 1990–1990
2 sentences

1990Property insurance, unlike liability insurance, is unconcerned with establishing negligence or otherwise assessing tort liability." Garvey v. State Farm Fire and Casualty Co., 48 Cal.3d 395 , 257 Cal.Rptr. 292, 298 , 770 P.2d 704, 710 (1989) (citation omitted).

1990Property insurance, unlike liability insurance, is unconcerned with establishing negligence or otherwise assessing tort liability." Garvey v. State Farm Fire and Casualty Co., 48 Cal.3d 395 , 257 Cal.Rptr. 292, 298 , 770 P.2d 704, 710 (1989) (citation omitted).

11
Pan American Life Insurance Co. v. Youngbloodgreen
texapp · 1978 · cited in 1 Texas opinions naming this issue, 1982–1982
1 sentence

1982See Stroburg v. Insurance Co. of North America, 464 S.W.2d 827, 829 (Tex.1971); Pan American Life Insurance Co. v. Youngblood, 569 S.W.2d 951, 956 (Tex.Civ.App. — Tyler 1978, writ ref’d n.r.e.).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
Rsui Indemnity Company v. the Lynd Company green
tex · 2015
1 sentence

2024Finally, Marsh, which is aligned with Patterson in this appeal, argues that Patterson must prevail unless Ohio Casualty “could establish an unambiguous exception to the coverage for defense costs found in the Underlying Policy.” It cites Insurance Code § 554.002, which places the burden of establishing an exclusion on the insurer, and our decision in RSUI, where we explained that we construe an ambiguous contract in favor of the insured. 466 S.W.3d at 140 .

12024–2024
McMillin v. State Farm Lloyds green
texapp · 2005
1 sentence

2015No claim to original U.S. Government Works. 24 McMillin v. State Farm Lloyds, 180 S.W.3d 183 (2005) Although we will render judgment that the McMillins are entitled to $990.13 for expenses incurred to prevent further damage, the date by which State Farm received all documents relating to the Coverage A claim is not relevant to the $990.13 recovery; the jury was not asked to find the date by which State Farm received all documents relating to their claim for damage-prevention expenses, and the McMillins do not complain about the absence of such a question or finding.

12015–2015
Lunsford v. Morris green
tex · 1988
1 sentence

2015No claim to original U.S. Government Works. 1 Aranda v. O'Neill, Not Reported in S.W.2d (1988) sought was overly broad, burdensome, oppressive, or sought Aranda asserts that the trial court abused its discretion in discovery of irrelevant material. failing to grant all of its requested discovery because the insurance companies, by not producing evidence in support In Lunsford v. Morris, 746 S.W.2d 471 (Tex.1988), the of their motion for protection, failed to follow the proper supreme court found that a defendant's net worth is relevant procedure to obtain the protective order as required by to

12015–2015
Weisel Enterprises, Inc. v. Curry green
tex · 1986
1 sentence

2015No claim to original U.S. Government Works. 1 Aranda v. O'Neill, Not Reported in S.W.2d (1988) sought was overly broad, burdensome, oppressive, or sought Aranda asserts that the trial court abused its discretion in discovery of irrelevant material. failing to grant all of its requested discovery because the insurance companies, by not producing evidence in support In Lunsford v. Morris, 746 S.W.2d 471 (Tex.1988), the of their motion for protection, failed to follow the proper supreme court found that a defendant's net worth is relevant procedure to obtain the protective order as required by to

12015–2015
Texas Farmers Insurance Co. v. Cooper green
texapp · 1996
1 sentence

2012Id.

12012–2012
OneBeacon Insurance v. Don's Building Supply, Inc. green
ca5 · 2007
1 sentence

2008In this case there may be little practical difference between an actual-injury rule and an exposure rule, because, as the Fifth Circuit notes, the homeowners’ petitions alleged that “injury to the home actually began to occur on the occasion of the first penetration of moisture behind the [EIFS] which would have been at such time as the improperly installed sealant joints and sealants began to fail, allowing moisture within the system.” OneBea-con, 496 F.3d at 362 .

12008–2008
Brown v. Houston Independent School District green
texapp · 2003
1 sentence

2005Brown, 123 S.W.3d at 622 -23 (citing Lindsey, 997 S.W.2d at 157 ).

12005–2005
Torchia v. Aetna Casualty & Surety Co. green
texapp · 1991
1 sentence

1997Id. at 222 .

11997–1997
National Union Fire Insurance Co. v. Dominguez green
tex · 1994
1 sentence

1996Id.

11996–1996
Lyons v. Millers Casualty Insurance Co. of Texas green
tex · 1993
1 sentence

1993Although this evidence is acknowledged to be relevant to the validity of Lyons' coverage claim, the majority declares that neither this nor any other evidence is relevant to Millers' bad faith: Lyons offered no evidence that the reports of Millers' experts were not objectively prepared, or that Millers' reliance on them was unreasonable, or any other evidence from which a factfinder could infer that Millers acted without a reasonable basis and that it knew or should have known that it lacked a reasonable basis for its actions. 866 S.W.2d at 601 .

11993–1993
Schwartz v. Jefferson green
tex · 1975
1 sentence

1989Id.

11989–1989
Missouri State Life Ins. Co. v. Nidiffer green
tenn · 1935
2 sentences

1942The coverage clause of the contract quoted above clearly obligated the company to pay the sum stipulated “immediately” upon being furnished proof that the insured was totally and permanently disabled, and, that such a state of disability has existed “for a period of six months.” As stated in Missouri State Life Insurance Company v. Nidiffer, 168 Tenn. 584 , 79 S. W. (2d) 1024 , “Before there can be anything due under the policy for total and permanent disability, such disability must have lasted for six months.” The period of permanent disability covered has a definite time of beginning.

1942The coverage clause of the contract quoted above clearly obligated the company to pay the sum stipulated “immediately” upon being furnished proof that the insured was totally and permanently disabled, and, that such a state of disability has existed “for a period of six months.” As stated in Missouri State Life Insurance Company v. Nidiffer, 168 Tenn. 584 , 79 S. W. (2d) 1024 , “Before there can be anything due under the policy for total and permanent disability, such disability must have lasted for six months.” The period of permanent disability covered has a definite time of beginning.

11942–1942
Manufacturers National Bank v. United States Fidelity & Guaranty Co. neutral
nyappdiv · 1926
1 sentence

1941In the first case cited by the defendant the court there defines “misplacement” to mean “to put a thing in the wrong place, or to locate unsuitedly.” In the case cited by us in 218 N.Y.S. 332 , at page 334, par. 2, the Court says: “The meaning of ‘misplacement’ cannot be questioned; It means ‘put in a wrong place.’ ” These definitions are essentially that given by Webster, and are the meanings that are commonly and ordinarily given the term.

11941–1941
Neighbors of Woodcraft v. Hildebrahdt neutral
colo · 1936
2 sentences

1940In support of the theory that the assured, having accepted a reinstatement, was bound thereby, two cases are cited: Supreme Ruler of Mystic Circle v. Darwin, 201 Ala. 687 , 79 So. 259 , and Neighbors of Woodcraft v. Hildebrandt, 98 Colo. 231 , 54 P.2d 889 .

1940In support of the theory that the assured, having accepted a reinstatement, was bound thereby, two cases are cited: Supreme Ruler of Mystic Circle v. Darwin, 201 Ala. 687 , 79 So. 259 , and Neighbors of Woodcraft v. Hildebrandt, 98 Colo. 231 , 54 P.2d 889 .

11940–1940
Supreme Ruler of Mystic Circle v. Darwin neutral
ala · 1918
2 sentences

1940In support of the theory that the assured, having accepted a reinstatement, was bound thereby, two cases are cited: Supreme Ruler of Mystic Circle v. Darwin, 201 Ala. 687 , 79 So. 259 , and Neighbors of Woodcraft v. Hildebrandt, 98 Colo. 231 , 54 P.2d 889 .

1940In support of the theory that the assured, having accepted a reinstatement, was bound thereby, two cases are cited: Supreme Ruler of Mystic Circle v. Darwin, 201 Ala. 687 , 79 So. 259 , and Neighbors of Woodcraft v. Hildebrandt, 98 Colo. 231 , 54 P.2d 889 .

11940–1940

Where else courts name it

CA 101 (1959–2025) FL 36 (1963–2025) WI 32 (1932–2022) LA 32 (1942–2021) TX 24 (1940–2025) NJ 18 (1924–2026) PA 18 (1967–2025) IL 18 (1981–2023) AZ 16 (1978–2017) NY 12 (1917–2026) MO 10 (1930–2014) HI 10 (1970–2015) WA 9 (1941–2023) GA 9 (1973–2018) NM 8 (1987–2024) DE 7 (1970–2024) MD 7 (1971–2006) MN 7 (1998–2014) IA 6 (1997–2016) KY 6 (1943–2025) AL 6 (1950–2003) MA 6 (1988–2012) KS 5 (1981–2007) IN 4 (2008–2017) CO 4 (1999–2009) OH 4 (1990–2026) ND 4 (1992–2024) MI 4 (1985–1998) AK 3 (1993–2003) WY 3 (1968–1993) VA 2 (1936–2023) OR 2 (2008–2015) ME 2 (2006–2012) NE 2 (2013–2018) VT 2 (2002–2004) DC 2 (1987–2023) UT 2 (2012–2012) SC 2 (1991–2019) WV 2 (1952–1998)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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