Gulf Metals Industries Inc., Gulf Reduction Corporation, and Gulf Reduction Corporation as a Successor to Southern Zinc Company v. Chicago Insurance Company, Interstate Fire & Casualty Company, Delta Lloyds Insurance Company, First State Insurance Company, Insurance Company of North America, Continental Casualty Company, Transcontinental Insurance Company

CourtCourt of Appeals of Texas
DecidedMay 13, 1999
Docket03-98-00013-CV
StatusPublished

This text of Gulf Metals Industries Inc., Gulf Reduction Corporation, and Gulf Reduction Corporation as a Successor to Southern Zinc Company v. Chicago Insurance Company, Interstate Fire & Casualty Company, Delta Lloyds Insurance Company, First State Insurance Company, Insurance Company of North America, Continental Casualty Company, Transcontinental Insurance Company (Gulf Metals Industries Inc., Gulf Reduction Corporation, and Gulf Reduction Corporation as a Successor to Southern Zinc Company v. Chicago Insurance Company, Interstate Fire & Casualty Company, Delta Lloyds Insurance Company, First State Insurance Company, Insurance Company of North America, Continental Casualty Company, Transcontinental 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.

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Gulf Metals Industries Inc., Gulf Reduction Corporation, and Gulf Reduction Corporation as a Successor to Southern Zinc Company v. Chicago Insurance Company, Interstate Fire & Casualty Company, Delta Lloyds Insurance Company, First State Insurance Company, Insurance Company of North America, Continental Casualty Company, Transcontinental Insurance Company, (Tex. Ct. App. 1999).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-98-00013-CV

Gulf Metals Industries, Inc., Gulf Reduction Corporation, and Gulf Reduction Corporation as a Successor to Southern Zinc Company, Appellants



v.



Chicago Insurance Company, Interstate Fire & Casualty Company, Delta Lloyds Insurance Company, First State Insurance Company, Insurance Company of

North America, Continental Casualty Company, Transcontinental Insurance

Company, CNA Lloyds of Texas, Transportation Insurance Company,

Fidelity & Casualty Insurance Company of New York and

Glen Falls Insurance Company, Appellees



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 126TH JUDICIAL DISTRICT

NO. 96-04673A, HONORABLE F. SCOTT McCOWN, JUDGE PRESIDING


DISSENTING OPINION

I agree that the majority's interpretation of the phrase "sudden and accidental" in the qualified pollution exclusion is eminently reasonable, perhaps more reasonable than the insured's definition. Indeed, I would have joined the majority had this opinion been handed down before the supreme court issued its decision in Balandran v. Safeco Insurance Co. of America, 972 S.W.2d 738 (Tex. 1998). Because I find that Balandran compels a finding that the insured's reading of "sudden and accidental" is also reasonable, I would hold that the trial court erred in granting summary judgment in favor of CIC. (1) I respectfully dissent.

Significance of Balandran

Balandran involved a simple issue: whether a standard homeowner's policy covered damage to a foundation caused by an underground plumbing leak. One year earlier, the Fifth Circuit had addressed the identical question and held that under its reading of Texas law the policy provision unambiguously excluded damage to a foundation caused by a plumbing leak. See Sharp v. State Farm Fire & Cas. Ins. Co., 115 F.3d 1258 (5th Cir. 1997). The court held that the insured's interpretation was not reasonable; therefore, the exclusion was unambiguous, and the insured was not entitled to the benefit of the ambiguity. See id. at 1262-63.

In Balandran the supreme court examined the same provision and reached a different result, essentially holding that the Fifth Circuit misapplied Texas law in Sharp. Furthermore, the court gave a generous reading of what can be considered a "reasonable interpretation" of a coverage exclusion by an insured. Courts "must adopt the construction . . . urged by the insured as long as that construction is not unreasonable, even if the construction urged by the insurer appears to be more reasonable or a more accurate reflection of the parties' intent." Balandran, 972 S.W.2d at 741 (quoting National Union Fire Ins. Co. v. Hudson Energy Co., 811 S.W.2d 552, 555 (Tex. 1991) (emphasis added)). The policy at issue in Balandran excluded water damage to the dwelling; the insureds conceded that the damage to their foundation fell under this exclusion unless language in the personal property section created an exception to the exclusion when the structural damage resulted from a plumbing leak. The exclusion repeal that the insureds relied on covered personal property against accidental discharge or leakage or overflow of water or steam from within a plumbing system. This part of the policy further provided that "Exclusions 1.a through l.h under Section I Exclusions do not apply to loss caused by this peril." Exclusion 1.h excluded structural damage resulting from a plumbing leak. The Balandrans did not suffer any personal property loss, but relied on this sentence to argue that exclusion 1.h did not apply to the loss damage to their home caused by a plumbing leak. The insurer insisted, relying on the Fifth Circuit's earlier opinion in Sharp, that an exception found in the personal property coverage section of the policy could not be used to avoid the exclusion found in the dwelling coverage section. In that case, the circuit court had concluded:



We are sympathetic to the Sharps' situation, but we cannot agree that text specifically included in Coverage B, which applies only to personal property, may be imported into Coverage A, which applies to the dwelling or house, in order to create coverage for a loss that does not involve personal property damage. The Sharps' policy clearly and unambiguously divides dwelling losses and personal property losses into two separate 'coverages.' It therefore would appear to be nonsensical, and a rejection of the obvious structure of the policy, to reach into text that applies solely to [personal property losses] to determine the extent of coverage under [the dwelling section].



Sharp, 115 F.3d at 1262.

To find the insured's interpretation "reasonable" and the policy provision ambiguous, the supreme court in Balandran applied standard rules of contract construction: (1) insurance contracts are subject to the same rules of construction as other contracts, (2) the primary goal is to give effect to the written expression of the parties intent, and (3) the court will strive to give meaning to every sentence, clause and word to avoid rendering any portion inoperative. See Balandran, 972 S.W.2d at 741. The court went on to add: "While parol evidence of the parties' intent is not admissible to create an ambiguity, the contract may be read in light of the surrounding circumstances to determine whether an ambiguity exists." Id. (emphasis added, citations omitted). Furthermore, the court thought it proper to consider the circumstances surrounding the promulgation of the policy form in determining whether the Balandrans' interpretation was reasonable. Noting that insurers must use forms adopted by the State Board of Insurance, that an earlier version of the form contained exclusion-repeal language that unquestionably applied to dwelling coverage as well as personal property loss, and that the revision of the form was intended to simplify the policy language and not to restrict any coverage previously available, the court concluded that "the Balandrans' interpretation becomes even more reasonable when we consider the circumstances surrounding the promulgation of this policy form." Id.

Balandran recognizes that insurance is a regulated industry and that the regulatory entity that promulgates mandatory policy forms is a silent party to a contract that must be written on such forms.

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Sharp v. State Farm Fire & Casualty Insurance
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Mesa Operating Co. v. California Union Insurance Co.
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533 S.W.2d 344 (Texas Supreme Court, 1976)

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Gulf Metals Industries Inc., Gulf Reduction Corporation, and Gulf Reduction Corporation as a Successor to Southern Zinc Company v. Chicago Insurance Company, Interstate Fire & Casualty Company, Delta Lloyds Insurance Company, First State Insurance Company, Insurance Company of North America, Continental Casualty Company, Transcontinental Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gulf-metals-industries-inc-gulf-reduction-corporation-and-gulf-reduction-texapp-1999.