Great American Insurance Company of New York v. Nationwide Mutual Insurance Company

CourtCourt of Appeals of Texas
DecidedFebruary 9, 2023
Docket09-20-00293-CV
StatusPublished

This text of Great American Insurance Company of New York v. Nationwide Mutual Insurance Company (Great American Insurance Company of New York v. Nationwide Mutual 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
Great American Insurance Company of New York v. Nationwide Mutual Insurance Company, (Tex. Ct. App. 2023).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-20-00293-CV __________________

GREAT AMERICAN INSURANCE COMPANY OF NEW YORK, Appellant

V.

NATIONWIDE MUTUAL INSURANCE COMPANY, Appellee __________________________________________________________________

On Appeal from the 284th District Court Montgomery County, Texas Trial Cause No. 20-02-02039-CV __________________________________________________________________

OPINION

At issue in this appeal is whether the Uniform Condominium Act

makes an agreement to settle a subrogation claim, which the Act requires

to be waived, enforceable. 1 On cross-motion for summary judgment, the

1Tex. Prop. Code Ann. § 82.111(d) (requiring the insurer to waive its right to subrogation under the policy against a unit owner); id. § 82.004 (prohibiting persons from varying the requirements of Chapter 82 by agreement “[e]xcept as expressly provided by this chapter”[]). 1 trial court refused to enforce the agreement and rendered a take-nothing

judgment against the plaintiff who sued the defendant to enforce a

settlement agreement of an insurance subrogation claim the Act required

the insurance company that brought the suit to waive.

Finding no error, we affirm.

Background

The Fire

Dana and Donna Evans own a unit at The Shore, a high-rise

condominium in Austin, Texas. In May 2019, an accidental fire, which

investigators determined originated in the Evanses’ unit, damaged

property in several units and in the common areas on several floors of

The Shore. 2

The duties of the entity responsible for managing The Shore, duties

that include obtaining insurance against risks of loss like fires, are

2In general, the Declaration filed of record for The Shore created a separate ownership interest for the property that each unit owner kept inside the walls of the owner’s unit. That said, the owner of a unit also owns an undivided interest in the Common Elements. The Declaration defined the Common Elements broadly to mean “[a]ll portions of the Condominium, including both the General Common Elements and Limited Common Elements, and including the Residential Unit’s interest in the Master Common Elements but excluding the Units.” 2 created by filing a document referred to as a declaration in the real

property records of the county where the condominium is built. 3 A limited

partnership formed The Shore in 2006, dedicating the property to be used

as a condominium by filing a “Condominium Declaration” (the

Declaration) in the real-property records of Travis County, Texas. Under

the Declaration, the purchasers of units at The Shore became members

of The Shore Condominium Association, Inc. (the Association). Under the

Declaration, the Association is responsible for managing the

Association’s affairs. The owners of the units must pay Association dues,

which are used among other things to purchase insurance to cover the

property at The Shore. To comply with that obligation, the Association

bought an insurance policy from Great American Insurance Company of

New York, which insured the property The Shore was required to insure

under the Uniform Condominium Act against the risk of loss from fires,

less the policy’s deductible.

After the May 2019 fire, Great American paid the claims presented

to it that were covered under its policy from the fire. The claims Great

American paid came from owners of units who had property damaged in

3Id. §§ 82.051(a), .111. 3 their units, including the Evanses. Great American also paid to repair

damages that occurred to property in the common areas of the floors

damaged in the fire. In the areas outside the units, the owners of the

units hold an undivided interest, which The Shore’s Declaration defines

as Common Elements. 4

The Declaration also required the Evanses to obtain insurance on

the property in their unit. And the Declaration required them to obtain

“insurance covering damage to other Units or property located therein,

the cause of which originates from such Owner’s Unit.” To comply with

their obligations under the Declaration, the Evanses bought a

condominium policy issued by Nationwide Mutual Insurance Company.

Nationwide’s policy covered the Evanses for up to $300,000 per

occurrence for their negligent “ownership, maintenance or use of real or

personal property[.]”

The Settlement

Great American’s settlement is tied to an email dated December 16,

2019, that its attorney Chris Surber, sent Nationwide’s adjuster, Ross

Ver Helst. In the email, Great American offered “to resolve any and all

4See n.2. 4 claims and causes of action it has or may have against Dana and Donna

Evans arising out of and related to the [May 2019] fire for the total

amount of $373,212.93 or Dana and Donna Evans’ insurance policy

liability limit, whichever is less.” 5 On January 16, 2020, Ver Helst

sent Surber an email and responded to his settlement demand:

Chris, this is confirmation that we are accepting your demand for the damages to The [Shore] Condominium Association for the remainder of our insured’s liability limit. We have previously settled subrogation claims for two of the condo unit owners and have remaining liability limit[s] of $266,540.25 of our insured’s $300,000 liability policy limit. 6

5See Tex. Prop. Code Ann. § 82.111(a) (requiring the unit owners association, to maintain property insurance on the insurable common elements if that insurance is reasonably available); § 82.111(b) (when the building contains units with “horizontal boundaries described in the declaration,” the unit owners association must maintain insurance when it is reasonably available that “include[s] the units,” but the insurance “need not include improvement and betterments installed by unit owners”). 6Surber’s demand letter and Ver Helst’s emails refer to the

condominium association responsible for managing The Shore as “The Waterfront Master Condominium Association.” The Clerk’s Record, however, shows that as of May 2019 the correct legal name for the condominium where the fire occurred is The Shore’s Condominium Owner’s Association, Inc. The Clerk’s Record includes a corrective amendment, which shows The Waterfront Master Condominium Association, Inc. became The Shore Condominium Association, Inc. in 2006. In August 2019, an endorsement was added to Great American’s policy naming “The Shore Condominium Association” as a named insured under Great American’s policy, with the name change retroactive to the policy’s inception. For clarity and to avoid confusion, we have chosen to

5 On receiving Ver Helst’s email, Surber sent Ver Helst the following

email:

My client accepts your offer of $266,540.25. Please make the check payable to “Gauntt, Koen, Binney & Kidd LLP as trustee for Great American Insurance Company of New York” and mail the same to my attention at the below address. A copy of my firm’s W9 is attached. If you require a release, please send the same as soon as you can.

Finally, can you tell me if you paid the other condo owners 100% of their claim, based on a pro rata basis, etc?

On January 17, 2019, Dana Evans sent Ver Helst the following

I do not believe that the Great American Insurance Co. of New York has the right to a claim against my policy.

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Great American Insurance Company of New York v. Nationwide Mutual Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/great-american-insurance-company-of-new-york-v-nationwide-mutual-insurance-texapp-2023.