in Re Continental Casualty Company

CourtCourt of Appeals of Texas
DecidedSeptember 23, 2010
Docket14-10-00709-CV
StatusPublished

This text of in Re Continental Casualty Company (in Re Continental Casualty 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 Continental Casualty Company, (Tex. Ct. App. 2010).

Opinion

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed September 23, 2010.

In The

Fourteenth Court of Appeals

NO. 14-10-00709-CV

In Re Continental Casualty Company, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

MEMORANDUM OPINION

On July 29, 2010, relator Continental Casualty Company 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.  In the petition, relator seeks a writ of mandamus ordering the respondent, the Honorable Thomas R. Culver, presiding judge of the 240th District Court of Fort Bend County, to abate the underlying case and enforce the appraisal clause in the insurance contract between Continental Casualty and its insured, the real party in interest, Zoya Enterprises, Ltd..  We conditionally grant the writ.

I.  Background

Continental issued a commercial property insurance policy to Zoya covering several pieces of commercial property, which Zoya alleges were damaged by Hurricane Ike on September 13, 2008.  The policy requires the insured to provide notice to Continental when a loss occurs by providing a sworn proof of loss.  If the parties disagree as to the amount of the loss, either party may demand an appraisal as provided in the policy’s appraisal clause, which reads as follows:

If we and you disagree on the amount of loss, either may make written demand for an appraisal of the loss. In this event, each party will select a competent and impartial appraiser and notify the other of the appraiser selected within 20 days of such demand. The two appraisers select an umpire. If they cannot agree within 15 days upon such umpire, either may request that selection be made by a judge of a court having jurisdiction: Each appraiser will state the amount of loss. If they fail to agree, they will submit their differences to the umpire. A decision agreed to by any two will be binding. Each party will:

a. Pay its chosen appraiser; and

b. Bear the other expenses of the appraisal and umpire equally.

If there is an appraisal,

a. You will still retain your right to bring a legal action against us, subject to the provisions of the Legal Action Against Us Commercial Property Condition; and

b. We will still retain our right to deny the claim.

II.  Analysis

A.  The Appraisal Process

Almost all insurance policies contain provisions specifying appraisal as a means of resolving disputes regarding the “amount of loss” for a covered claim.  See State Farm Lloyds v. Johnson, 290 S.W.3d 886, 888 (Tex. 2009).  As in this case, appraisal provisions generally provide that either the insured or the insurer may demand an appraisal pursuant to the terms of the policy.  See In re Allstate Cty. Mut. Ins. Co., 85 S.W.3d 193, 195 (Tex. 2002) (orig. proceeding).  Where an insurance contract mandates appraisal to resolve the parties’ dispute regarding the value of a loss, and the appraisal provision has not been waived, a trial court abuses its discretion and misapplies the law by refusing to enforce the appraisal provision.  Scottish Union & Nat’l Ins. Co. v. Clancy, 83 Tex. 113, 18 S.W. 439, 440 (1892).  More recently, the supreme court has expressed a strong policy in favor of enforcing appraisal clauses in insurance contracts.  See State Farm Lloyds, 290 S.W.3d at 891–93 (holding that insurer is bound by appraisal clause to have amount of loss determined, even when dispute also involves questions of causation).

The Texas Insurance Code mandates prompt payment of claims.  See Tex. Ins. Code Ann. §§ 542.051–.061 (Vernon 2009).  An insurer is required to acknowledge receipt of a claim, begin an investigation, and request documentation from its insured within 15 days of notification of the claim.  Tex. Ins. Code Ann. § 542.055(a) (Vernon 2009).  The insurer is to notify the claimant in writing of the acceptance or rejection of the claim within 15 days after it receives the required documentation for proof of loss.  Id. § 542.056(a).  If the insurer notifies the claimant it requires more time, the acceptance or rejection must be made within 45 days of the notice.  Id. § 542.056(d).  Section 542.057 provides that a claim must be paid within five business days after notice that the claim, or a part of the claim, will be paid.  Tex. Ins. Code Ann. § 542.057(a) (Vernon 2009).  An insurer’s failure to comply with the statutorily prescribed timeframes will subject the insurer to damages, including interest on the amount of the claim and attorney’s fees.  See Tex. Ins. Code. Ann. §§ 542.058(a), 542.060 (Vernon 2009).

B.  The Claim

Shortly after Hurricane Ike struck, Zoya reported damage to 14 locations insured by Continental.  In November or December of 2008, Continental tendered payment on claims submitted for most of those locations.  With regard to the locations on which Continental did not tender payment, it was understood that the parties agreed with regard to the amount of loss.  Five months later, on May 1, 2009, Zoya’s counsel sent a letter to Continental informing Continental that it had been retained to represent Zoya and was investigating the damages to the 14 locations caused by Hurricane Ike.  The letter requested that Continental provide a payment log indicating all payments made and to whom they were made.  Zoya further requested documentation relating to the claims including all investigative reports regarding the claims. 

On June 10, 2009, Continental’s attorney responded to the May 1 letter stating that Continental had inspected the damage incurred as a result of Hurricane Ike and listed co-insurance valuations relating to five of the locations claimed to have been damaged.  Continental stated that those locations were not properly valued or insured at the time of the loss.  The letter contained a statement of reservation of rights in which Continental stated its investigation of the claim was subject to a complete reservation of all rights in the policy, and that Continental did not “intend to waive, and expressly reserves, any and all rights or defenses that may be available to it under the terms and conditions of the policy, the common law, or any applicable statute.”

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