Arch Reinsurance Company v. Underwriters Service Agency, Inc.

CourtCourt of Appeals of Texas
DecidedApril 26, 2012
Docket02-10-00365-CV
StatusPublished

This text of Arch Reinsurance Company v. Underwriters Service Agency, Inc. (Arch Reinsurance Company v. Underwriters Service Agency, Inc.) 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
Arch Reinsurance Company v. Underwriters Service Agency, Inc., (Tex. Ct. App. 2012).

Opinion

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

NO. 02-10-00365-CV

ARCH REINSURANCE COMPANY APPELLANT

V.

UNDERWRITERS SERVICE APPELLEE AGENCY, INC.

----------

FROM THE 48TH DISTRICT COURT OF TARRANT COUNTY

MEMORANDUM OPINION1

This appeal arises out of a dispute over a contract among three parties—

State National (not involved in this appeal), Appellant Arch Reinsurance

Company, and Appellee Underwriters Service Agency, Inc.—and a subsequent

modification of that contract negotiated by representatives of Arch and

Underwriters. In thirteen issues, Arch argues that the contract could not be

1 See Tex. R. App. P. 47.4. modified without State National’s consent; that the evidence is insufficient to

support the jury’s finding that Arch agreed to the modification; that the jury’s

findings that Arch agreed to modify the contract were immaterial; that the

modification violated the contract’s prohibition against assignments; that

Underwriters’s estoppel defense failed as a matter of law; that the jury’s finding

against Underwriters’s in one of the equitable estoppel questions in the charge

defeated Underwriters’s estoppel defense; that the jury’s finding in favor of

Underwriters on equitable estoppel in another question was immaterial; that the

trial court erred by excluding evidence about why State National did not consent

to the modification; that lack of consideration rendered the modification invalid;

that the modification was not retroactive; that the trial court erred by granting

summary judgment on Arch’s fraudulent inducement claims; that the trial court

erred by awarding attorney’s fees to Underwriters; and that Arch is entitled to an

award of attorney’s fees as a matter of law. Because we hold that the trial court

abused its discretion by awarding attorney’s fees to Underwriters, we modify the

trial court’s judgment to omit that award. Because we hold that State National’s

consent was not required for the modification and that the trial court did not err by

granting summary judgment on Arch’s fraud claims, we affirm the remainder of

the trial court’s judgment.

2 Background

The Agreement

State National issues insurance policies, Underwriters sells insurance

policies, and Arch provides reinsurance coverage.2 These three parties entered

into a Quota Share and Reinsurance Agreement (reinsurance agreement), as

well as a general agency agreement (agency agreement), which was attached to

and referenced by the reinsurance agreement. Under these agreements,

Underwriters sold (and collected the premiums on) homeowner policies issued by

State National, and Arch agreed to reinsure State National for one hundred

percent of the risk associated with the policies. Underwriters turned the

premiums over to Arch, receiving a commission on these premiums.

The agreement provided that Underwriters would receive a thirty percent

commission on the premiums it collected, but only provisionally, and this

provisional commission would be adjusted depending on the amount of losses

taken on the policies. If, at the end of the year, Arch suffered fewer losses than

expected compared to premiums earned, Arch would pay Underwriters an

additional percentage on a sliding scale, up to an additional three-and-a-half

percent. If, on the other hand, losses were higher than expected, Underwriters

2 See Gamma Grp., Inc. v. Transatlantic Reinsurance Co., 242 S.W.3d 203, 205 n.1 (Tex. App.—Dallas 2007, pet. denied) (“‘Reinsurance’” is a means whereby a company that issues an insurance policy can allocate or ‘cede’ a portion of the risk it bears on that policy to another insurance company in return for a portion of the premium.”).

3 had to return to Arch up to three percent of the commissions it had received, so

that Underwriters received only a twenty-seven percent commission.

Within forty-five days after the end of each month, Underwriters was

required to remit to Arch the ceded net premiums during that month, less

Underwriters’s commission and certain deductions. Arch was required to provide

a report to State National that included the amount of the commission paid to

Underwriters, and this report was required to be furnished within forty-five days of

the close of the month.

The agreement contained a provision that neither Arch nor Underwriters

could assign any of its rights or obligations under the agreement without prior

written consent of State National. It further provided that the agreement could be

amended or modified only by a written agreement executed by all the parties.

The Dispute

In 2007, Phil Glick, a property underwriter employed by Arch, had

discussions with representatives of Underwriters about Underwriters’s desire to

modify the reinsurance agreement. Underwriters requested that Arch agree to

increase Underwriters’s minimum commission from twenty-seven percent to thirty

percent. On December 11, 2007, Glick and a representative from Underwriters

signed a document, Addendum No. 11, to modify the reinsurance agreement.

The addendum provided that “[e]ffective as of March 1, 2007, and pertaining to

all liabilities that are applicable to [the reinsurance agreement], the loss and loss

adjustment expense are capped” per a scale set out in the addendum. This

4 scale capped Arch’s losses for certain years at specified amounts. The

addendum also amended paragraph 8.06 of the reinsurance agreement, the

provision that provided the adjusted commission rate used to determine the

amount of Underwriters’s commission. This amendment raised Underwriters’s

minimum commission to thirty percent, as had been requested by Underwriters.

On December 14, 2007, three days after signing Addendum No. 11, Glick

emailed his resignation to John Rathgeber, chairman of Arch, stating among

other things that “[b]ecause of the problems with the . . . . [State National]

contracts I feel as if my job performance has not been acceptable to myself.”

When Rathgeber met with Glick to discuss the email, he learned about Glick’s

execution of Addendum No. 11. Shortly after that, Rathgeber contacted

representatives with both Underwriters and State National and stated that Arch

did not agree to the addendum and that Glick was not authorized to agree to it.

State National had not reviewed or signed the addendum.

The Lawsuit

In 2008, Arch filed suit against Underwriters for breach of contract and for

declaratory relief. Arch alleged that for the agreement years 2003 through 2006,

Underwriters did not furnish reports to Arch and did not return commissions that

Arch was owed. Through amended petitions, Arch also challenged Addendum

No. 11 on fraudulent inducement grounds.

Underwriters filed a combined traditional and no-evidence motion for

summary judgment on the fraudulent inducement claims. Among other grounds,

5 Underwriters alleged that Arch’s fraud claims were barred by the economic loss

rule and that there was no evidence of the elements of fraud. In a separate

motion, Underwriters also sought summary judgment on the issue of whether

Glick had apparent authority to act on Arch’s behalf with respect to Addendum

No. 11. The trial court granted these motions without specifying the grounds.

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