in Re Allstate Texas Lloyd's

Procedural entryThis page is a short order in in Re Allstate Texas Lloyd's. Read the opinion of the Court — 202 S.W.3d 895
Court of Appeals of Texas·Decided September 2, 2005·No. 14-05-00762-CV·Published

Opinion

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed September 2, 2005

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed September 2, 2005.

In The

Fourteenth Court of Appeals

____________

NO. 14-05-00762-CV

IN RE ALLSTATE TEXAS LLOYD=S, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

M E M O R A N D U M   O P I N I O N

On July 29, 2005, relator filed a petition for writ of mandamus in this court.  See Tex. Gov=t. Code Ann. ' 22.221 (Vernon 2004); see also Tex. R. App. P. 52.  Relator complains of the trial court=s denial of a motion to sever.  Real parties have filed a response.  We conditionally grant relief.


This proceeding arises from a suit for damages filed by real parties in interest, James and Song Suk Roberts, based on an alleged breach of a homeowner=s insurance policy.  Real parties allege breach of contract as well as extra-contractual claims of bad faith.  After pretrial mediation, relator made a settlement offer to real parties on all disputed breach of contract claims, but the offer was rejected.  Thereafter, relator filed a motion to sever the extra-contractual claims from the breach of contract claims.  The trial judge signed an order on July 1, 2005, denying the motion for severance.[1]  Relator contends the trial judge abused her discretion by failing to sever the extra-contractual claims from the breach of contract claims. 

Mandamus is an extraordinary remedy, available only in limited circumstances to correct a clear abuse of discretion or the violation of a legal duty when no other adequate remedy at law is available.  In re FirstMerit Bank, N.A., 52 S.W.3d 749, 753 (Tex. 2001).   Rules 41 and 174(b) of the Texas Rules of Civil Procedure vest the trial court with broad discretion to sever and order separate trials of causes of action.  The trial court's discretion is not unlimited, however.  Womack v. Berry, 291 S.W.2d 677, 683 (Tex.1956).  The supreme court has stated:

When all the facts and circumstances of the case unquestionably require a separate trial to prevent manifest injustice, and there is no fact or circumstance supporting or tending to support a contrary conclusion, and the legal rights of the parties will not be prejudiced thereby, there is no room for the exercise of discretion. The rule then is peremptory in operation and imposes upon the court a duty to order a separate trial. While the refusal to grant a separate trial under such circumstances is usually termed a clear abuse of discretion, it is nevertheless a violation of a plain legal duty.

Id.


A trial court properly exercises its  discretion in severing claims when: A(1) the controversy involves more than one cause of action; (2) the severed claim is one that could be asserted independently in a separate lawsuit; and (3) the severed actions are not so interwoven with the other claims that they involve the same facts and issues.@  Liberty Nat=l Fire Ins. Co. v. Akin, 927 S.W.2d 627, 629 (Tex. 1996).  Insurance coverage claims and bad faith claims are, by their nature, independent claims.  In re Republic Lloyds, 104 S.W.3d 354, 358 (Tex. App.BHouston [14th Dist.] 2003, orig. proceeding).  Furthermore, an insured usually may not prevail on an extra-contractual claim without first proving the insurer breached the contract.  Id. 

No one disputes that there are multiple claims at issue in this case.  Furthermore, case law indicates that the contract and extra-contractual claims can be asserted independently.  Thus, the first two requirements for severance are met.  Although the claims in this case could be asserted independently, the claims are largely interwoven as most of the evidence introduced will be admissible on both claims.  See Akin, 927 S.W.2d at 630.  Nonetheless, severance may be necessary in some bad faith cases, such as when the insurer has made a settlement offer on the disputed contract claim.  Id. at 630.  The supreme court has approved case law from courts of appeals holding that severance is required when an insurer has made a settlement offer.  Id. (citing Mid-Century Ins. Co. v. Lerner, 901 S.W.2d 749 (Tex. App.BHouston [14th Dist.] 1995, orig. proceeding); Northwestern Nat=l Lloyds Ins. Co. v. Caldwell, 862 S.W.2d 44 (Tex. App.BHouston [14th Dist.] 1993, orig. proceeding); F.A. Richard & Assocs. v. Millard, 856 S.W.2d 765 (Tex. App.BHouston [1st Dist.] 1993, orig. proceeding); United States Fire Ins. Co. v. Millard, 847 S.W.2d 668 (Tex. App.BHouston [1st Dist.] 1993, orig. proceeding); and State Farm Mut. Ins. Co. v. Wilborn

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Related

Womack v. Berry
291 S.W.2d 677 (Texas Supreme Court, 1956)
FA Richard and Associates v. Millard
856 S.W.2d 765 (Court of Appeals of Texas, 1993)
In Re Republic Lloyds
104 S.W.3d 354 (Court of Appeals of Texas, 2003)
Universe Life Insurance v. Giles
950 S.W.2d 48 (Texas Supreme Court, 1997)
State Farm Mutual Automobile Insurance Co. v. Wilborn
835 S.W.2d 260 (Court of Appeals of Texas, 1992)
Northwestern National Lloyds Insurance Co. v. Caldwell
862 S.W.2d 44 (Court of Appeals of Texas, 1993)
Liberty National Fire Insurance Co. v. Akin
927 S.W.2d 627 (Texas Supreme Court, 1996)
Allstate Insurance Co. v. Evins
894 S.W.2d 847 (Court of Appeals of Texas, 1995)
In Re Firstmerit Bank, N.A.
52 S.W.3d 749 (Texas Supreme Court, 2001)
Avary v. Bank of America, N.A.
72 S.W.3d 779 (Court of Appeals of Texas, 2002)
United States Fire Insurance Co. v. Millard
847 S.W.2d 668 (Court of Appeals of Texas, 1993)
Mid-Century Insurance Co. of Texas v. Lerner
901 S.W.2d 749 (Court of Appeals of Texas, 1995)