Benchmark Insurance Company v. Linan

CourtDistrict Court, S.D. Texas
DecidedJune 23, 2025
Docket4:24-cv-01884
StatusUnknown

This text of Benchmark Insurance Company v. Linan (Benchmark Insurance Company v. Linan) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benchmark Insurance Company v. Linan, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT June 23, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

BENCHMARK INSURANCE § COMPANY, § Plaintiff, § § VS. § CIVIL ACTION NO. 4:24-CV-01884 § JORGE ADRIAN LINAN, et al., § Defendants. §

MEMORANDUM OPINION AND ORDER Pending before the Court is Plaintiff Benchmark Insurance Company’s Motion for Summary Judgment (Dkt. 29). After careful consideration of the motion, the record, and the applicable law, the Court GRANTS the motion (Dkt. 29). I. FACTUAL BACKGROUND Plaintiff Benchmark Insurance Company (“Benchmark”) issued a homeowners insurance policy (“the Policy”) to Defendant Yazmin Linan, insuring a property located in Katy, Texas (“the Property”). (Dkt. 29 at p. 3). Though the Policy provides that coverage extends only to “[t]he one-family dwelling where [Defendant Yazmin Linan] reside[s] … on the inception date of the policy period,” Defendant Yazmin Linan testified in a deposition that she did not reside at the Property on the inception date of the Policy’s policy period. (Id. at pp. 5 - 7). Defendants are being sued in state court under theories of premises liability and gross negligence for an alleged incident that occurred on the Property and resulted in bodily injury of a third party (“the Underlying Lawsuit”). (Id. at p. 6); see Juan Ramon Guevara 1 / 7 Ortez v. Linses Land LLC, Jorge Adrian Linan, and Yazmin Linan a/k/a Irasema Yazmin Sesatty, Cause No. 23-DCV-307962, 400th Judicial District Court of Fort Bend County, Texas. Benchmark brings this action seeking a declaration that it is not liable for defense

or indemnity benefits under the Policy. (Dkt. 29 at p. 1). Benchmark argues it is entitled to such declaration both because the Policy bars coverage of the Property and because Defendants failed to cooperate in the investigation, settlement, or defense of the Underlying Lawsuit.1 (Id. at pp. 8 – 18). Defendants did not respond. II. LEGAL STANDARD

Summary judgment is proper when “there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). A dispute about a material fact is “genuine” if the evidence, taken as a whole, could lead a rational trier of fact to find for the nonmoving party. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986). For summary judgment, the initial burden falls on

the movant to identify areas essential to the non-movant’s claim in which there is an absence of a genuine issue of material fact. Lincoln Gen. Ins. Co. v. Reyna, 401 F.3d 347, 349 (5th Cir. 2005). The movant, however, need not negate the elements of the non- movant’s case. See Boudreaux v. Swift Transp. Co., 402 F.3d 536, 540 (5th Cir. 2005). The movant may meet its burden by pointing out the absence of evidence supporting the non-

movant’s case. Duffy v. Leading Edge Products, Inc., 44 F.3d 308, 312 (5th Cir. 1995).

1 The Court does not reach Benchmark’s argument on Defendants’ alleged failure to cooperate because it decides this motion on other grounds. 2 / 7 In deciding whether a genuine and material fact issue has been created, the facts and inferences to be drawn from those facts must be reviewed in the light most favorable to the non-movant. Reaves Brokerage Co. v. Sunbelt Fruit & Vegetable Co., 336 F.3d 410, 412

(5th Cir. 2003). “[C]onclusory allegations” or “unsubstantiated assertions” do not meet the non-movant’s burden. Delta & Pine Land Co. v. Nationwide Agribusiness Ins. Co., 530 F.3d 395, 399 (5th Cir. 2008). Instead, the non-movant must present specific facts which show the existence of a genuine issue concerning every essential component of its case. Am. Eagle Airlines, Inc. v. Air Line Pilots Ass’n, Int’l, 343 F.3d 401, 405 (5th Cir. 2003).

Further, Rule 56 does not impose upon the Court a duty to sift through the record in search of evidence to support a party’s opposition to summary judgment; evidence not referred to in the response to the motion for summary judgment is not properly before the Court, even if it exists in the summary judgment record. Malacara v. Garber, 353 F.3d 393, 405 (5th Cir. 2003).

Summary judgment may not be awarded by default simply because there is no opposition. Hibernia Nat’l Bank v. Administration Cent. Sociedad Anonima, 776 F.2d 1277, 1279 (5th Cir. 1985). Nevertheless, “a court may grant an unopposed summary judgment motion if the undisputed facts show that the movant is entitled to judgment as a matter of law.” Day v. Wells Fargo Bank Nat’l Ass’n, 768 F.3d 435, 435 (5th Cir. 2014)

(citation omitted). III. ANALYSIS

3 / 7 The Court finds that Benchmark does not owe Defendants defense or indemnity benefits under the Policy because Defendant Yazmin Linan did not live at the Property on the Policy’s policy inception date. Accordingly, Benchmark’s motion must be granted.

A. Duty to Defend The Court finds that Benchmark does not owe Defendants the duty to defend under the Policy. Under Texas law, insurance policies are construed in accordance with the same rules as contracts generally. Canutillo Independent School Dist. v. National Union Fire Insurance Co. of Pittsburgh, Pa., 99 F.3d 695, 700 (5th Cir. 1996). A court’s primary

concern in construing a written contract is to ascertain the true intent of the parties as expressed in the instrument. Federal Insurance Co. v. Northfield Insurance Co., 837 F.3d 548, 552 (5th Cir. 2016). The insured bears the initial burden of showing that the claim against it is potentially within the insurance policy’s scope of coverage. Federal Insurance, 837 F.3d at 552. If there is doubt as to whether a third party’s allegations against the insured

state a cause of action within the coverage of a liability policy sufficient to compel the insurer to defend the action, such doubt will be resolved in the insured’s favor. Id. In determining whether an insurer has a duty to defend an insured against a third- party complaint, Texas courts follow the “eight-corners” rule. Canutillo, 99 F.3d at 701. The eight-corners rule determines whether the insurer has a duty to defend by comparing

the allegations in the third party’s pleadings with the language of the insurance policy. National Union Fire Insurance Co. of Pittsburgh, Pa. v. Merchants Fast Motor Lines, Inc., 939 S.W.2d 139, 141 (Tex. 1997). When applying the eight-corners rule, “the court must

4 / 7 focus on the factual allegations that show the origin of the damages rather than on the legal theories alleged.” Id.

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Malacara v. Garber
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Benchmark Insurance Company v. Linan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/benchmark-insurance-company-v-linan-txsd-2025.