Bertha Arce, Individually and as Representative of All Others Similarly Situated v. American National Insurance Company

CourtCourt of Appeals of Texas
DecidedAugust 24, 2021
Docket07-19-00362-CV
StatusPublished

This text of Bertha Arce, Individually and as Representative of All Others Similarly Situated v. American National Insurance Company (Bertha Arce, Individually and as Representative of All Others Similarly Situated v. American National Insurance Company) 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
Bertha Arce, Individually and as Representative of All Others Similarly Situated v. American National Insurance Company, (Tex. Ct. App. 2021).

Opinion

In The Court of Appeals Seventh District of Texas at Amarillo ________________________

No. 07-19-00362-CV ________________________

BERTHA ARCE, INDIVIDUALLY AND AS REPRESENTATIVE OF ALL OTHERS SIMILARLY SITUATED, APPELLANT

V.

AMERICAN NATIONAL INSURANCE COMPANY, APPELLEE

On Appeal from the 46th District Court Hardeman County, Texas Trial Court No. 11529; Honorable Dan Mike Bird, Presiding

August 24, 2021

OPINION Before PIRTLE and PARKER and DOSS, JJ.

Appellant, Bertha Arce, Individually and as Representative of All Others Similarly

Situated challenges the trial court’s rendition of summary judgment in favor of Appellee,

American National Insurance Company, on her claims for breach of contract and

violations of the Texas Insurance Code, as well as her claim for recovery of attorney’s fees and class action claims. Through two issues, Arce contends the trial court erred in

(1) overruling her objections to American National’s summary judgment evidence, and (2)

granting American National summary judgment on her claims. We reverse the judgment

of the trial court and remand for further proceedings consistent with this opinion.

BACKGROUND

This is a case involving the denial of a claim under a life insurance policy issued

by American National. In December 2016, Sergio Arce, Jr., Bertha Arce’s son, applied

for a life insurance policy with American National. Arce was the beneficiary of that policy.

Part of the application required that he answer the question of whether, in the last ten

years, he had been diagnosed, treated, tested positive for, or been given medical advice

for any disease or abnormality of the stomach, intestines, rectum, pancreas, or liver,

including cirrhosis, hepatitis, and colitis. Sergio answered that question with “no” and

signed a statement affirming that his answers in the application were “full, complete and

true to the best of [his] knowledge and belief.” However, medical records showed Sergio

had been diagnosed with hepatitis C three years earlier, in 2013. At that time, he did not

treat that condition or heed medical advice that he seek treatment or assistance in

obtaining treatment. Under American National’s underwriting guidelines, it would not

have issued the policy to Sergio if he had disclosed his hepatitis C diagnosis.

The agent who sold Sergio the policy stated she asked Sergio all of the application

questions and recorded the answers he provided. She did not, however, determine

whether he fully understood each question. American National issued a life insurance

policy to Sergio based on his application. He also signed a form indicating his

understanding that the premium he had been quoted had been modified from the original

2 amount to a premium of $91 per month and that the accidental death benefit coverage

had been denied.

The policy was issued on January 4, 2017. It contained an incontestability

provision providing that the policy could not be contested after it had been in force during

the insured’s lifetime for a period of two years. Prior to the expiration of that two-year

period, American National was entitled to contest the policy for material misstatements

made in the application.

Unfortunately, Sergio was in a car accident and died thirteen days after the policy

was issued. Arce submitted a claim for benefits. American National denied the claim in

July 2017, enclosing the applicable portions of the policy and Sergio’s medical records,

as well as refunding the $91 premium paid, with interest. The denial letter explained that

while Sergio indicated on his application that he did not suffer from liver disease, including

cirrhosis or hepatitis, medical records showed a history of liver disease, untreated

hepatitis C, and continued drinking despite counseling that Sergio cease doing so. It also

explained that had Sergio provided accurate information on the application, the policy

would not have been issued under American National’s underwriting guidelines.

Arce filed suit against American National in November 2017, alleging breach of

contract, violations of sections 541.060, 541.061, and 542.060 of the Texas Insurance

Code, and seeking recovery of policy benefits, statutory penalties, and attorney’s fees.

Arce later amended her petition to add claims for class relief. In February 2019, American

National filed a traditional motion for summary judgment, arguing Arce’s claims were

barred because Sergio made material misrepresentations in his application for the life

insurance policy. The trial court granted American National’s motion in July 2019, stating

3 it was disposing of all claims and all parties. The trial court subsequently denied Arce’s

motion for new trial and for reconsideration and overruled her objections to American

National’s summary judgment evidence. Thereafter, Arce timely filed her notice of

appeal.

STANDARD OF REVIEW—TRADITIONAL MOTION FOR SUMMARY JUDGMENT

We review a trial court’s ruling on a motion for summary judgment under a de novo

standard of review. Valence Operating Co. v. Dorsett, 164 S.W.3d 656, 661 (Tex. 2005).

To prevail on a traditional motion for summary judgment the movant must “show that,

except as to the amount of damages, there is no genuine issue as to any material fact

and the moving party is entitled to judgment as a matter of law . . . .” TEX. R. CIV. P.

166a(c); Cmty. Health Sys. Pro’l Servs. Corp. v. Hansen, 525 S.W.3d 671, 681 (Tex.

2017) (citing Provident Life, 128 S.W.3d at 216); Lightning Oil Co. v. Anadarko E&P

Onshore, LLC, 520 S.W.3d 39, 45 (Tex. 2017)). A fact is conclusively established if

reasonable minds could not differ about the conclusion to be drawn from the record. City

of Keller v. Wilson, 168 S.W.3d 802, 816 (Tex. 2005). In our review of a trial court’s grant

of summary judgment, we take as true all evidence favorable to the nonmovant and

indulge every reasonable inference and resolve any doubts in the nonmovant’s favor.

Valence, 164 S.W.3d at 661.

4 ANALYSIS

ISSUE ONE—ARCE’S OBJECTIONS TO AMERICAN NATIONAL’S SUMMARY JUDGMENT EVIDENCE

Through her first issue, Arce argues the trial court erred in overruling her objections

to American National’s summary judgment evidence.1 American National argues the

record shows the summary judgment evidence Arce is challenging on appeal was proper

and the trial court did not err in overruling the objections.

An appellate court should review a trial court’s decision to admit or exclude

summary judgment evidence under an abuse of discretion standard. Van Adrichem v.

Agstar Fin. Servs., FLCA, No. 07-13-00432-CV, 2015 Tex. App. LEXIS 11734, at *3 (Tex.

App.—Amarillo Nov. 13, 2015, no pet.) (mem. op.) (citing McCraw Materials, L.L.C. v.

DivLend Equip. Leasing, L.L.C., No. 07-12-00215-CV, 2013 Tex. App. LEXIS 779, at *11,

(Tex. App.—Amarillo Jan. 28, 2013, no pet.) (mem. op.), (citing In re J.P.B., 180 S.W.3d

570, 575 (Tex. 2005)). We must uphold a trial court’s evidentiary ruling if there is any

legitimate basis for it. Owens-Corning Fiberglas Corp. v.

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