Allstate Indemnity Company v. Mary Hyman

CourtCourt of Appeals of Texas
DecidedMarch 21, 2006
Docket06-05-00064-CV
StatusPublished

This text of Allstate Indemnity Company v. Mary Hyman (Allstate Indemnity Company v. Mary Hyman) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allstate Indemnity Company v. Mary Hyman, (Tex. Ct. App. 2006).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana


______________________________


No. 06-05-00064-CV



ALLSTATE INDEMNITY COMPANY, Appellant

V.

MARY HYMAN, Appellee




On Appeal from the 62nd Judicial District Court

Lamar County, Texas

Trial Court No. 69197





Before Morriss, C.J., Ross and Carter, JJ.

Memorandum Opinion by Justice Carter



MEMORANDUM OPINION


            Mary Hyman, an insured of Allstate Indemnity Company, was involved in an automobile accident July 26, 2000. Hyman made a claim for her severely damaged Ford Explorer, but thought Allstate's offer was inadequate. After several months of unfruitful negotiation, which included letters and telephone calls, this lawsuit was filed just over a year later. Six months after that, in February 2002, the storage facility demanded that Hyman pay the storage fees on the vehicle or relinquish her claim to the vehicle in exchange for cancellation of the debt. She relinquished the vehicle.

            Hyman also sued the driver of the other car, Marilyn Baker. On September 25, 2003, Hyman settled her claims against Baker. Hyman's lawsuit against Allstate went to trial October 11, 2004. Hyman claimed Allstate breached its contract with her. A jury agreed, and it also found a knowing violation of Article 21.21 of the Texas Insurance Code. The jury awarded her actual damages of $21,600.00 ($18,000.00 for the vehicle and $3,600.00 for a rental vehicle for a reasonable period of time), enhanced damages of $54,000.00, and also awarded $25,000.00 in attorney's fees. The trial court ordered an offset in the amount of Hyman's settlement with Baker.

            Both Allstate and Hyman appeal.

            Allstate raises a number of contentions on appeal:

            (1)       the evidence was factually and legally insufficient to show that it breached its contract and that the evidence conclusively shows Hyman breached it;

            (2)       Hyman impaired Allstate's subrogation rights;

            (3)       the evidence concerning the value of the vehicle is not factually sufficient;

            (4)       the evidence is factually and legally insufficient to support a finding of a violation of Article 21.21 of the Texas Insurance Code;

            (5)       the amount of damages for vehicle rental is improper and excessive; and

            (6)       the award of damages exceeds the statutory cap.

            Hyman contends that the trial court erred by not awarding damages under Article 21.55 of the Texas Insurance Code, as well as under Article 21.21.

1.         Breach of Contract

            Allstate first contends that the evidence is legally and factually insufficient to allow the jury to find that it breached its contract with Hyman, and suggests that the evidence conclusively proves it did comply with the terms of the contract. Allstate focuses on evidence that, after Hyman filed a claim and Allstate sent her a letter with a list of information it wanted, she did not provide all of the information—thus, Allstate argues, Hyman never triggered Allstate's duty to pay the claim and Allstate did not breach by not paying.

            Specifically, Allstate in its August 7 letter asked Hyman to provide information about the lienholder on her vehicle, authorization to speak to the lienholder about her account, possession of the vehicle, and a power of attorney to permit Allstate to sell the vehicle. Allstate argues that these are all items Allstate would need to complete its investigation and secure final proof of loss on Hyman's claim.

            a.         Standards of Review

            In determining a no-evidence issue attacking a jury's finding, we are to consider only the evidence and inferences that tend to support the finding and disregard all evidence and inferences to the contrary. Bradford v. Vento, 48 S.W.3d 749, 754 (Tex. 2001); Cont'l Coffee Prods. Co. v. Cazarez, 937 S.W.2d 444, 450 (Tex. 1996). Anything more than a scintilla of evidence is legally sufficient. Cazarez, 937 S.W.2d at 450.

            When considering a factual sufficiency challenge to a jury's verdict, we consider and weigh all of the evidence, not just that evidence which supports the verdict. Mar. Overseas Corp. v. Ellis, 971 S.W.2d 402, 406–07 (Tex. 1998). We may set aside the verdict only if it is so contrary to the overwhelming weight of the evidence that the verdict is clearly wrong and unjust. Cain v. Bain, 709 S.W.2d 175, 176 (Tex. 1986); Ellis, 971 S.W.2d at 407.

            b.        Sufficiency of the Evidence

            Allstate first contends it did not breach its contract with Hyman. Allstate argues that, because it sent a letter requesting various authorizations and because Hyman did not provide those items, Allstate conclusively proved Hyman never triggered Allstate's obligation to pay, and thus the failure to pay is not a breach of contract.

            In the letter on which Allstate relies, Allstate told Hyman what was needed "to conclude your claim, if liability is accepted for your loss." The letter states that it enclosed a "Power of Attorney to Transfer Motor Vehicle" form and that it was necessary to return the form to enable Allstate to issue payment and keys. The letter also demands that Hyman return either a clear title, or contact information about any lienholder, and that she contact the lienholder to authorize release of the payoff information to the insurer's representative. The letter finally directs her to call any location where the vehicle is stored with directions to release the vehicle to Allstate. It then contains incomplete telephone numbers at which Hyman could contact some unidentified person for more information.

            The letter does not support Allstate's position. It contains nothing that relates to the issue before the court and jury: Allstate's investigation of the claim and its decision to accept or not accept her claim. All of the items demanded (several of which were actually already in Allstate's files) have to do, as clearly stated in the letter, with the procedure that would ultimately be followed after Allstate accepted liability for the loss. Thus, Hyman's failure to provide a release of information and authority over the vehicle—to which Allstate had not yet become entitled—is not conclusive evidence of a breach by Hyman.

            

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