Cynthia T. Wills v. USAA General Indemnity

CourtCourt of Appeals of Texas
DecidedDecember 7, 2023
Docket01-22-00304-CV
StatusPublished

This text of Cynthia T. Wills v. USAA General Indemnity (Cynthia T. Wills v. USAA General Indemnity) 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
Cynthia T. Wills v. USAA General Indemnity, (Tex. Ct. App. 2023).

Opinion

Opinion issued December 7, 2023

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-22-00304-CV ——————————— CYNTHIA T. WILLS, Appellant V. USAA GENERAL INDEMNITY COMPANY, Appellee

On Appeal from the County Civil Court at Law No. 3 Harris County, Texas Trial Court Case No. 1156962

MEMORANDUM OPINION

A homeowner appeals the trial court’s no-evidence summary judgment in

favor of her insurer on contractual and extra-contractual claims related to the

adjustment and payment of a claim on her homeowner’s insurance policy. In a single

issue, the homeowner contends that fact issues precluded the no-evidence summary judgment. Because we conclude that the evidence the homeowner relies on to raise

fact issues is conclusory, and thus no evidence, we affirm.

Background

A fire damaged Cynthia T. Wills’s home. USAA General Indemnity

Company (USAA) insured the home under a homeowner’s insurance policy, with a

$135,000 limit for loss to the dwelling.1 But the policy included a “home protector”

endorsement providing that if the amount of the covered loss exceeded the dwelling

coverage for certain reasons, USAA would pay “up to an additional 25% of the

amount of insurance applying to the damaged building.” The most USAA would pay

under the endorsement was “25% or the amount actually and necessarily spent to

repair or replace the damaged building, whichever is less.” By USAA’s calculation,

the limit of the policy’s dwelling coverage could be raised only as high as

$168,750.00 ($135,000 plus 25%). USAA adjusted the fire loss claim and issued

payments totaling $163,589.03 to Wills.

Claiming she was owed additional amounts under the policy that USAA

refused to pay, Wills sued. She alleged that USAA had breached the insurance

policy; violated the Texas Prompt Payment of Claims Act (TPPCA); committed

unfair or deceptive acts or practices under Chapter 541 of the Texas Insurance Code

1 The policy also provided coverage for other structures, for personal property, and loss of use. 2 and the Texas Deceptive Trade Practices Act (DTPA); breached its duty of good

faith and fair dealing; committed fraud; and engaged in a “conspiracy to commit

illegal acts.”

Eighteen months after Wills sued, USAA moved for a no-evidence summary

judgment on all claims. Wills responded and attached three exhibits as summary

judgment evidence: (1) the insurance policy, (2) her own affidavit, and (3) an

affidavit and estimate from her public adjuster.

USAA objected to some of Wills’s summary judgment evidence. Specifically,

USAA objected that the public adjuster’s affidavit was vague and conclusory

because it did not state the facts or methodology relied on to determine that the cost

to repair the “covered damages” was $182,580.44, almost $19,000 more than USAA

had paid. USAA also objected that several paragraphs in Wills’s affidavit were

vague and conclusory, including the paragraphs stating that:

• She “fully cooperated with [USAA] and investigators during the handling of [her] claim, including complying with all conditions precedent in [the insurance policy]”;

• USAA had “not paid [her] in full to repair or replace [her] property to date”;

• USAA “admit[ted] fire caused covered damages to [her] home yet refuse[d] to pay [her] a fair value to have [her] property made whole”;

• USAA acted in bad faith because it “advertises one thing but practices another”;

3 • She “relied on [USAA] in that [USAA] insured [her] and would pay a fair and reasonable amount for valid insurance claims”;

• She “relied on all of [USAA’s] representations”;

• She would not have purchased the insurance policy “[i]f not for [USAA’s] misrepresentations”;

• She “repeatedly attempted to change [USAA’s] mind and pay [her] adequately under [the insurance policy] by and through [her] attorney”;

• USAA “nonetheless repeatedly stood by [its] claim determination and refuse[d] to consider evidence [she] provided” that supported her claim;

• She “believed [USAA] made material representations”;

• If she “was not adequately covered for damages to [her] home resulting from a fire, then [she] would not have purchased insurance from [USAA]”;

• USAA falsely represented that it would “adequately compensate [her] for [her] valid insurance claim” and “pay full damages resulting from [a certain] peril.”

Before the trial court ruled on USAA’s objections, it gave Wills an

opportunity to supplement or amend her summary judgment evidence. At the

deadline, Wills supplemented her response but did not attach any amended or

additional evidence. Instead, she relied on the same affidavits.

The trial court ultimately granted some of USAA’s objections to Wills’s

summary judgment evidence, denied other objections, and granted USAA’s

no-evidence motion on all claims. Wills appealed.

4 Adequacy of Appellant’s Brief

We note there is a question here on the adequacy of Wills’s appellant’s brief.

An appellant’s brief must “contain a clear and concise argument for the contentions

made, with appropriate citations to authorities and to the record.” TEX. R. APP. P.

38.1(i). This standard is not met when the appellant’s brief contains only conclusory

statements that are not supported by legal citations. Tesoro Petroleum Corp. v.

Nabors Drilling USA, Inc., 106 S.W.3d 118, 128 (Tex. App.—Houston [1st Dist.]

2002, pet. denied). Failure to cite legal authority or provide substantive analysis of

the issue presented waives the complaint. See Guimaraes v. Brann, 562 S.W.3d 521,

538 (Tex. App.—Houston [1st Dist.] 2018, pet. denied); see also Abdelnour v. Mid

Nat’l Holdings, Inc., 190 S.W.3d 237, 242 (Tex. App.—Houston [1st Dist.] 2006,

no pet.) (finder waiver when appellant’s brief provided “no citation to the record,

nor any discussion of relevant or analogous authorities to assist the Court in

evaluating its claim”).

Wills presents a single issue in her opening brief: “Did the trial court abuse

[its] discretion by granting [USAA’s] summary judgment motion?” The issue is

framed using an incorrect standard of review and is supported only by a brief

conclusory argument, which reads in full:

The trial court erroneously granted [USAA’s] no-evidence summary judgment motion based on the Court’s mistaken belief that [USAA] demonstrated the absence of material fact issues in [Wills’s] petitions. The trial court committed a reversible error here because the error

5 amounted to such a denial of [her] rights as was reasonably calculated and certainly caused the rendition of an improper judgment. Therefore, [Wills] respectfully requests that this Court overrule the trial court’s order granting [USAA] summary judgment and find the trial court’s granting of [USAA’s] no-evidence summary judgment motion an abuse of its discretion[2] and thereby reversible error and order the trial court to reinstate [her] case. The argument is not specific as to any of the dismissed claims. Nor does it contain

any substantive argument or citation to the appellate record or appropriate

authorities. See TEX. R. APP. P. 38.1(i).

USAA pointed out these deficiencies in its response brief and urged this Court

to reject Wills’s appeal on briefing waiver. USAA also defended the merits of the

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