Farmers Group, Inc., Farmers Underwriters Association, Fire Underwriters Association, Farmers Insurance Exchange, and Fire Insurance Exchange v. Sandra Geter, on Behalf of Herself and All Others Similarly Situated, Gerald Hooks, Jr., Lesly K. Nolen, and Joseph C. Blanks, P.C.

CourtTexas Supreme Court
DecidedApril 9, 2021
Docket19-0996
StatusPublished

This text of Farmers Group, Inc., Farmers Underwriters Association, Fire Underwriters Association, Farmers Insurance Exchange, and Fire Insurance Exchange v. Sandra Geter, on Behalf of Herself and All Others Similarly Situated, Gerald Hooks, Jr., Lesly K. Nolen, and Joseph C. Blanks, P.C. (Farmers Group, Inc., Farmers Underwriters Association, Fire Underwriters Association, Farmers Insurance Exchange, and Fire Insurance Exchange v. Sandra Geter, on Behalf of Herself and All Others Similarly Situated, Gerald Hooks, Jr., Lesly K. Nolen, and Joseph C. Blanks, P.C.) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Farmers Group, Inc., Farmers Underwriters Association, Fire Underwriters Association, Farmers Insurance Exchange, and Fire Insurance Exchange v. Sandra Geter, on Behalf of Herself and All Others Similarly Situated, Gerald Hooks, Jr., Lesly K. Nolen, and Joseph C. Blanks, P.C., (Tex. 2021).

Opinion

IN THE SUPREME COURT OF TEXAS ══════════ No. 19-0996 ══════════

FARMERS GROUP, INC., FARMERS UNDERWRITERS ASSOCIATION, FIRE UNDERWRITERS ASSOCIATION, FARMERS INSURANCE EXCHANGE, AND FIRE INSURANCE EXCHANGE, PETITIONERS, v.

SANDRA GETER, ON BEHALF OF HERSELF AND ALL OTHERS SIMILARLY SITUATED, GERALD HOOKS, JR., LESLY K. NOLEN, AND JOSEPH C. BLANKS, P.C., RESPONDENTS ══════════════════════════════════════════ ON PETITION FOR REVIEW FROM THE COURT OF APPEALS FOR THE THIRTEENTH DISTRICT OF TEXAS ══════════════════════════════════════════

Argued February 3, 2021

JUSTICE BLACKLOCK delivered the opinion of the Court.

JUSTICE GUZMAN and JUSTICE BOYD did not participate in the decision.

This is the latest appeal in a long-running class-action suit. The primary issue is how to

interpret a homeowners insurance policy that has been out of use for nearly twenty years. For the

reasons explained below, we conclude that the insurer correctly interprets the policy and was

therefore entitled to summary judgment on the individual and class claims. We render a take-

nothing judgment on those claims and remand for the trial court to address any remaining matters. I. Background

A. Farmers’ Decision to Discontinue the HO-B Policy

Beginning in 2000, the Texas homeowners insurance market experienced a large increase

in mold claims. At the time, Farmers Group, Inc.1 (Farmers), like other insurers, offered a broad

“all risk” policy known as the HO-B policy. This policy was approved by the Texas Department

of Insurance (TDI) under its statutory authority to approve insurance forms. See TEX. INS. CODE

art. 5.35. Homeowners insurance policies cannot be issued in Texas without TDI approval. Id.

art. 5.35(e) (“Unless approved or adopted by the commissioner . . . an insurance policy or

endorsement . . . may not be delivered or issued for delivery in this state.”).

In November 2001, Farmers and other insurers decided to stop offering HO-B policies.

Farmers decided to offer instead a less comprehensive “named peril” policy known as the HO-A

policy. A letter from Farmers executive John Hageman to TDI stated that the decision to

discontinue the HO-B policy and offer the HO-A policy was “motivated primarily by the dramatic

increases that we have experienced for water, mold and foundation claims, and the resultant

underwriting losses.”2 TDI approved Farmers’ decision and mandated that all insurers remove the

HO-B policy from the market by the end of 2002. TDI approved an enhanced HO-A policy, one

1 Petitioners are Farmers Group, Inc., Farmers Underwriters Association, Fire Underwriters Association, Farmers Insurance Exchange, and Fire Insurance Exchange. Like the parties, we refer to the petitioners collectively as Farmers.

2 This Court later held that the HO-B policy did not cover mold claims. Fiess v. State Farm Lloyds, 202 S.W.3d 744 (Tex. 2006).

2 including coverage for some water claims, which Farmers intended to offer as a substitute for the

HO-B policy.

Pursuant to statute, an insurer may choose not to renew a policy so long as it provides the

insured a written notice no later than 30 days before the policy expires. TEX. INS. CODE art.

21.49-2B, § 5 (now TEX. INS. CODE § 551.105).3 In 2002, Farmers sent a notice of non-renewal

to its HO-B policyholders, including Respondent Sandra Geter. The notice stated that the

policyholders’ existing policies would not be renewed and that Farmers would no longer offer the

HO-B policy “[b]ecause of substantial losses which we have incurred for the homeowners and

dwellings lines of insurance in Texas.” The notice informed policyholders that Farmers would

continue to offer coverage under its HO-A policy.4 In August 2002, Geter filed this lawsuit in

Jefferson County after receiving Farmers’ non-renewal notice.

B. The Travis County Suit

In addition to the Geter suit now before the Court, a separate class-action suit was filed in

August 2002 in Travis County. The Travis County suit was originally brought by the State of

Texas on behalf of TDI as the sole plaintiff. It accused Farmers of various statutory violations

3 When the Insurance Code of 1951 was re-codified in 2003, one year after this case began, section 5 became section 551.105 of the new Code. See Act of May 22, 2003, 78th Leg., R.S., ch. 1274, § 2, sec. 551.105, § 26, 2003 Tex. Gen. Laws 3611, 3713, 4138. Under section 5, “[a]n insurer shall renew a policy on its expiration, at the option of the insured, unless the insurer has mailed written notice of nonrenewal to the insured not later than the 30th day before the date on which the policy expires.” Section 551.105 now states in part: “Unless the insurer has mailed written notice of nonrenewal or renewal with written notice of change in coverage as provided by Section 2002.001 to the insured not later than the 30th day before the date on which the insurance policy expires, an insurer must renew an insurance policy, at the request of the insured, on the expiration of the policy.”

4 In 2003, the Attorney General issued an opinion concluding that an insurer does not violate Texas law in refusing on a statewide basis to renew homeowners insurance policies, so long as it complies with the 30-day notice requirement. Tex. Att’y Gen. Op. No. GA-0045 (2003).

3 related to the premiums charged for homeowners policies. Specifically, it alleged that Farmers

wrongfully raised premiums despite offering less coverage when it replaced the HO-B policy with

the HO-A policy. TDI did not allege that Farmers improperly failed to renew the HO-B policies,

as Geter alleges. In 2002, the State amended the Travis County suit to include certain class-action

allegations. In 2003, class members Gerald Hooks and Lesly Hooks (later Lesly Nolen) alleged

that Farmers breached the HO-B policy by refusing to renew it. This breach-of-contract claim

mirrored the contract non-renewal claim that is the focus of the pending Geter case.

In 2016, after a series of appeals and many years of litigation, the trial court in the Travis

County suit rendered judgment approving a settlement agreement. The agreement released various

class claims against Farmers but excepted from the release the wrongful non-renewal claim

asserted in the Geter case.5

C. The Pending Geter Litigation

In August 2002, Respondent Sandra Geter filed the Jefferson County suit now before this

Court. She claimed that Farmers did not have the right to non-renew HO-B policies, including her

policy. She sought a declaratory judgment that the non-renewal was ineffective and that class

members were entitled to renew their HO-B policies. She sought and received class certification

from the trial court.

5 A supplement to the final settlement agreement amended the definition of released claims to state that “the claim for declaratory relief only . . . which has been certified as a class action . . . in the pending [Geter case] is not released.” It goes on to state: “The Farmers Parties agree that the settlement of this [Travis County] case will not be used to argue that the declaratory relief claim, which was certified as a class action . . . in the pending [Geter case] is barred by the doctrines of res judicata, collateral estoppel, or release . . . .”

4 The parties filed cross-motions for summary judgment. Farmers relied principally on its

statutory right to non-renew policies with 30-days’ notice. Geter relied principally on contract

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Farmers Group, Inc., Farmers Underwriters Association, Fire Underwriters Association, Farmers Insurance Exchange, and Fire Insurance Exchange v. Sandra Geter, on Behalf of Herself and All Others Similarly Situated, Gerald Hooks, Jr., Lesly K. Nolen, and Joseph C. Blanks, P.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/farmers-group-inc-farmers-underwriters-association-fire-underwriters-tex-2021.