in Re: Allstate County Mutual Insurance Company

CourtCourt of Appeals of Texas
DecidedNovember 15, 2006
Docket12-06-00164-CV
StatusPublished

This text of in Re: Allstate County Mutual Insurance Company (in Re: Allstate County 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
in Re: Allstate County Mutual Insurance Company, (Tex. Ct. App. 2006).

Opinion

MARY'S OPINION HEADING

                                                NO. 12-06-00164-CV

IN THE COURT OF APPEALS

TWELFTH COURT OF APPEALS DISTRICT

TYLER, TEXAS

IN RE: ALLSTATE COUNTY         §                     

MUTUAL INSURANCE      §                      ORIGINAL PROCEEDING

COMPANY    §                     

OPINION

            In this original proceeding, Allstate County Mutual Insurance Company (Allstate) seeks a writ of mandamus requiring the trial court to vacate its order denying Allstate’s motion to sever and abate Brandi M. Driskell’s claims for extracontractual damages until her claim for uninsured/underinsured motorist (UIM) benefits has been adjudicated.1  For the reasons set forth below, we conditionally grant the writ as to Allstate’s motion to sever, but deny the writ as to Allstate’s motion to abate.

Factual and Procedural Background

            On January 22, 2005, vehicles driven by Driskell and Etta Agnes Bates-Foley collided at the intersection of Old Troup Highway and ESE Loop 323 in Tyler.  Driskell contended that Foley was underinsured and filed a UIM claim with Allstate.  On September 30, 2005, Allstate offered Driskell $18,000.00 to settle the UIM claim.  Five days later, it raised its settlement offer to $20,000.00.


            On October 14, 2005, Driskell filed suit against Allstate for breach of contract under the UIM provision of her policy and also for violations of the Texas Deceptive Trade Practices Act, Texas Insurance Code, and general insurance principles.  Allstate responded with a general denial.  Allstate later filed a motion to sever and abate the extracontractual claims.

            As authority for its motion to sever and abate, Allstate cited Liberty National Fire Insurance Company v. Akin, 927 S.W.2d 627 (Tex. 1996).  Allstate contended that where the insurer has made a settlement offer on a disputed contractual claim, it is unduly prejudicial to litigate both the contractual and the extracontractual claims in the same lawsuit.  See id. at 630.  Driskell responded that the trial court should follow an unreported Texarkana Court of Appeals decision that allowed a bifurcated trial of contractual and extracontractual claims rather than severance of the claims into two causes of action.  See In re Allstate Ins. Co., No. 06-05-00051-CV, 2005 WL 1114640, at *2 (Tex. App.–Texarkana May 12, 2005, orig. proceeding) (mem. op.).  Allstate responded in a written reply that the Texarkana Court of Appeals allowed bifurcation rather than requiring severance because there was no evidence in the record before it of a settlement offer by the insurance company.

            The trial court entered an order denying Allstate’s motion to sever and abate, but bifurcating the contractual and extracontractual claims to be heard by the same jury in separate trials.  Allstate then filed this original proceeding.  On Allstate’s motion, we stayed the proceedings in the trial court until our disposition of its mandamus petition.

Availability of Mandamus

            A writ of mandamus will issue only if the trial court has committed a clear abuse of discretion and the relators have no adequate remedy by appeal.  In re Cerberus Capital Mgmt., L.P., 164 S.W.3d 379, 382 (Tex. 2005) (orig. proceeding).  The trial court abuses its discretion if it reaches a decision so arbitrary and unreasonable as to amount to a clear and prejudicial error of law or if it clearly fails to correctly analyze or apply the law.  Walker v. Packer, 827 S.W.2d 833, 839-40 (Tex. 1992).  To show that the trial court abused its discretion, the party challenging the trial court’s decision must establish that the facts and law permit the trial court to make but one decision.  In re University Interscholastic League, 20 S.W.3d 690, 692 (Tex. 2000).  Trial courts have broad discretion to sever a lawsuit into separate suits or to grant separate trials on claims or issues.  Akin, 927 S.W.2d at 629 (severance); Womack v. Berry, 156 Tex. 44, 291 S.W.2d 677, 683 (1956) (separate trials).

Severance or Bifurcation?

            Insurance is a contract by which one party, for consideration, assumes a particular risk on behalf of another party and promises to pay him a certain or ascertainable sum of money on the occurrence of a specified contingency.  Employers Reinsurance v. Threlkeld & Co., 152 S.W.3d 595, 597 (Tex. App.–Tyler 2003, pet. denied).  A claim for UIM benefits is contractual in nature.  In re Trinity Universal Ins. Co., 64 S.W.3d 463, 467 (Tex. App.–Amarillo 2001, orig. proceeding).  A UIM claim is separate and distinct from any extracontractual claims.  See id. at 467-68.

            The Texas Supreme Court has recognized that a severance of extracontractual claims from contractual claims may be necessary in certain insurance cases.  Akin, 927 S.W.2d at 630.  A trial court will undoubtedly confront instances in which evidence admissible only on the extracontractual claim would prejudice the insurer to such an extent that a fair trial on the contract claim would become unlikely.  Id. 

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Related

In Re Cerberus Capital Management, L.P.
164 S.W.3d 379 (Texas Supreme Court, 2005)
In Re University Interscholastic League
20 S.W.3d 690 (Texas Supreme Court, 2000)
Employers Reinsurance Corp. v. Threlkeld & Co. Insurance Agency
152 S.W.3d 595 (Court of Appeals of Texas, 2004)
Womack v. Berry
291 S.W.2d 677 (Texas Supreme Court, 1956)
Clanton v. Clark
639 S.W.2d 929 (Texas Supreme Court, 1982)
Hall v. City of Austin
450 S.W.2d 836 (Texas Supreme Court, 1970)
State Farm Mutual Automobile Insurance Co. v. Wilborn
835 S.W.2d 260 (Court of Appeals of Texas, 1992)
Kansas University Endowment Ass'n v. King
350 S.W.2d 11 (Texas Supreme Court, 1961)
Liberty National Fire Insurance Co. v. Akin
927 S.W.2d 627 (Texas Supreme Court, 1996)
Transportation Insurance Co. v. Moriel
879 S.W.2d 10 (Texas Supreme Court, 1994)
In Re Trinity Universal Insurance Co.
64 S.W.3d 463 (Court of Appeals of Texas, 2001)
Project Engineering USA Corp. v. Gator Hawk, Inc.
833 S.W.2d 716 (Court of Appeals of Texas, 1992)
United States Fire Insurance Co. v. Millard
847 S.W.2d 668 (Court of Appeals of Texas, 1993)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)

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in Re: Allstate County Mutual Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-allstate-county-mutual-insurance-company-texapp-2006.