Frederick Critchfield and Claudia Critchfield, Individually and as Personal Representatives of the Estate of Eric Critchfield v. Dennis E. Smith

CourtCourt of Appeals of Texas
DecidedApril 30, 2004
Docket12-03-00017-CV
StatusPublished

This text of Frederick Critchfield and Claudia Critchfield, Individually and as Personal Representatives of the Estate of Eric Critchfield v. Dennis E. Smith (Frederick Critchfield and Claudia Critchfield, Individually and as Personal Representatives of the Estate of Eric Critchfield v. Dennis E. Smith) 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
Frederick Critchfield and Claudia Critchfield, Individually and as Personal Representatives of the Estate of Eric Critchfield v. Dennis E. Smith, (Tex. Ct. App. 2004).

Opinion

NO. 12-03-00017-CV

                         IN THE COURT OF APPEALS

            TWELFTH COURT OF APPEALS DISTRICT

                                      TYLER, TEXAS

FREDERICK CRITCHFIELD AND               '                 APPEAL FROM THE 362ND

CLAUDIA CRITCHFIELD, INDIVIDUALLY

AND AS PERSONAL REPRESENTATIVES

OF THE ESTATE OF ERIC CRITCHFIELD,

APPELLANTS                                                   

                                                                             '                 JUDICIAL DISTRICT COURT OF

V.                                                                                           

DENNIS E. SMITH,

APPELLEE                                                       '                 DENTON COUNTY, TEXAS

                                                                     OPINION

In three issues, Frederick Critchfield and Claudia Critchfield, individually and as personal representatives of the estate of Eric Critchfield (Athe Critchfields@), appeal the trial court=s grant of partial summary judgment and bifurcation of liability and damage issues in their lawsuit against Dennis E. Smith (ASmith@).  We affirm in part, and reverse and remand in part.

Background 


In July 1993, the Critchfields contacted Smith for advice about insuring their home and automobiles.  Specifically, Mr. Critchfield wanted the Amaximum@ amount of underinsured/uninsured motorist (AUM/UIM@) coverage available to him.  After discussing their options, the Critchfields purchased an automobile insurance policy from Nationwide Insurance Company (ANationwide@) that provided $500,000.00 in bodily injury liability coverage and $100,000.00 per person in UM/UIM bodily injury coverage.  According to Mr. Critchfield, Smith advised him that the $100,000.00 in UM/UIM coverage was an appropriate amount because Mr. Critchfield was covered by a major medical insurance policy.  At no time did Smith inform him that he could have acquired $500,000.00 in UM/UIM coverage.  From 1993 to 1999, Mr. Critchfield continued to renew his automobile insurance policy with $500,000.00 in liability coverage and $100,000.00 in UM/UIM coverage.

On December 20, 1999, the Critchfield=s son, Eric, was injured during an automobile accident while riding as a passenger in another vehicle.  On December 28, Eric died as a result of those injuries.  In August 2000, Nationwide paid the Critchfields the limits of their UM/UIM coverage.  Sometime after Nationwide paid the Critchfields, the Critchfields= attorney told them that Smith could have and should have sold them a policy with a $500,000.00 UM/UIM limit that was equal to the limit of personal liability coverage on their automobile insurance policy.[1] 

On December 19, the Critchfields sued Smith, contending that Smith was negligent in failing to 1) adequately and properly advise them on the appropriate amount of UM/UIM coverage, 2) provide them with UM/UIM coverage in an amount equal to the $500,000.00 limit of personal liability coverage, and 3) increase their UM/UIM coverage at each policy renewal date from 1992 or 1993 to December of 1999.  The Critchfields also alleged breach of contract, breach of fiduciary duty, and negligent misrepresentation causes of action, including the recovery of reasonable attorney=s fees.

On February 4, 2002, Smith filed a motion for partial summary judgment on the Critchfield=s negligence, breach of contract, and breach of fiduciary duty claims.  The Critchfields responded to the motion on March 7.  That same day, the Critchfields amended their original petition, adding causes of action for negligence per se and violations of the Deceptive Trade Practices Act (DTPA).


On April 10, the trial court granted Smith=s motion as it pertained to the Critchfield=s negligence, negligence per se, and breach of contract claims; however, it denied summary judgment on the breach of fiduciary duty claim.  On April 22, the Critchfields filed a motion to reconsider the trial court=s April 10 ruling, and on April 29, Smith filed a motion to exclude the Critchfields= experts on damages and negligent misrepresentation.  On May 16, the trial court granted the Critchfields= motion to reconsider, but only on their negligent misrepresentation claim.  The trial court also granted Smith=s motion to exclude the Critchfields= damage experts but denied the motion with regard to the negligent misrepresentation experts.  On June 26, the trial court, sua sponte, bifurcated the issues of Smith=s liability and any resulting damages and also ordered that the same jury hear both trials. 

The trial began on July 22, and the jury returned a verdict on July 26.  The jury answered Ano@ when asked whether Smith had 1) engaged in any false, misleading or deceptive act or practice, 2) engaged in any unconscionable action or course of action, 3) made a negligent misrepresentation, or 4) failed to comply with his fiduciary duty to the Critchfields.  The jury also found that the Critchfields= own negligence served as the proximate cause of any damages they sustained.[2]

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Frederick Critchfield and Claudia Critchfield, Individually and as Personal Representatives of the Estate of Eric Critchfield v. Dennis E. Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frederick-critchfield-and-claudia-critchfield-indi-texapp-2004.