In Re David Dick v. the State of Texas

CourtCourt of Appeals of Texas
DecidedDecember 12, 2024
Docket01-24-00585-CV
StatusPublished

This text of In Re David Dick v. the State of Texas (In Re David Dick v. the State of Texas) 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 David Dick v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

Opinion issued December 12, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-24-00585-CV ——————————— IN RE DAVID DICK, Relator

Original Proceeding on Petition for Writ of Mandamus

MEMORANDUM OPINION Relator, David Dick, filed a petition for writ of mandamus challenging the

trial court’s July 24, 2024 order denying his motion to dismiss, filed pursuant to

Texas Rule of Civil Procedure 91a.1 In his motion, relator sought dismissal of the

claims asserted by real party in interest, Allied Trust Insurance Company (Allied),

1 See TEX. R. CIV. P. 91a. in the underlying lawsuit.2 Relator’s mandamus petition requests that this Court

issue a writ of mandamus directing the trial court to “vacate its order denying

[relator’s] Rule 91a motion to dismiss,” “[o]rder the trial court to enter an order

granting the Rule 91a motion and dismissing all of Allied’s claims against [r]elator

with prejudice,” and “[a]ward [r]elator his reasonable attorney’s fees and costs.”

The Court requested a response to the petition for writ of mandamus, and

Allied filed a response to the mandamus petition. Relator also filed a reply in support

of his petition.

We deny relator’s petition for writ of mandamus in part, and conditionally

grant relator’s petition for writ of mandamus in part.

Background

Relator obtained an insurance policy from Allied covering a residential

property located at 5603 Blossom Street, Houston, Texas 77007 (the property). The

policy documents reflect that the relevant coverage period for the Allied policy

began on March 24, 2023. The underlying litigation arises out of a claim made under

the Allied policy by relator in connection with an alleged loss at the property.

Specifically, the claim under the Allied policy alleged that the property sustained

covered roof damage on March 30, 2023.

2 The underlying case is Allied Trust Ins. Co. v. David Dick and Dick Law Firm, PLLC, Cause No. 1227457, in the County Civil Court at Law No. 2 of Harris County, Texas, the Honorable Jim Kovach presiding.

2 Separately, but also on March 30, 2023, Allied completed its underwriting

inspection of the property which, notably, “showed age, wear, and tear to the

property’s roof.” Based on this underwriting inspection, on June 15, 2023, Allied

notified relator of its intention to cancel the policy covering the property, submitting

its “Notice of Cancellation” of the policy “due to roof concerns.”

On June 20, 2023, after relator was notified that Allied was cancelling the

policy covering the property, relator submitted a claim under the Allied policy.

Relator’s claim alleged a loss occurred on March 30, 2023, during the coverage

period, to the roof of the property. Relator asserted that the loss was caused by wind.

On June 29, 2023, relator’s legal counsel, Dick Law Firm, PLLC (the Dick Law

Firm) sent a letter of representation to Allied.

On June 20, 2023, the same day the Allied claim was submitted, relator also

submitted a claim of loss on the property to a separate insurer, Swyfft, on behalf of

Clear Blue Insurance Company (Swyfft). The mandamus record reflects that the

Swyfft policy covered the property for the period of March 23, 2022 to March 23,

2023. In the Swyfft claim, relator alleged roof damage due to a windstorm on

January 24, 2023. On June 28, 2023, the Dick Law Firm sent a letter of

representation to Swyfft.

On July 13, 2023, the Dick Law Firm sent an estimate of damage to Allied.

The estimate was created by “R. Martinez Consulting” and alleged that the property

3 required repairs and remodeling in the amount of $99,303.71 to remedy the damage

sustained, purportedly caused by wind on March 30, 2023. The estimate alleged that

the property required a roof replacement, as well as interior repairs and remodeling

to the master bath, a hallway, and a balcony.

The Dick Law Firm simultaneously sent the R. Martinez Consulting estimate

to Swyfft in connection with relator’s claim of loss on that policy. The estimate

submitted to Swyfft, in support of relator’s alleged loss from a January 24, 2023

windstorm, was identical to the estimate submitted to Allied for damages

purportedly caused by wind on March 30, 2023. The R. Martinez Consulting

estimate does not reference the claim number for either relator’s claim under his

Allied policy or his claim made under the Swyfft policy. In its live pleading, Allied

alleged that, at the time the R. Martinez Consulting estimate was submitted to Allied,

Allied was not aware that relator had also made a claim on the Swyfft policy for the

same damage to the property.

In connection with the Allied claim, the property was inspected by an Allied

independent field adjuster. In a July 14, 2023 report, the independent adjuster

concluded that the replacement cost value of the damage to the property was

$17,358.21. Based on the conclusions from the independent field adjuster’s

inspection, on July 25, 2023, Allied made a payment to the Dick Law Firm in the

4 amount of $1,446.23, which represented the replacement cost value minus the

policy’s $8,860 deductible and $7,051.98 of “[r]ecoverable [d]epreciation.”

However, due to the apparent disagreement in the alleged amount of loss

($17,358.21 versus $99,303.71), Allied invoked the policy’s appraisal provision to

reach a potential agreement on the amount of loss. On August 30, 2023, an appraisal

award, signed by both Allied’s chosen appraiser and relator’s chosen appraiser,

concluded that the replacement cost to repair the property was $27,492.34. In

connection with the appraisal award, Allied submitted an additional payment of

$12,783.91 to the Dick Law Firm. This payment represented the replacement cost

value minus the $8,860 deductible, $4,492.20 of recoverable depreciation, and the

$1,446.23 prior payment by Allied.

While the appraisal process was ongoing, and unbeknownst to Allied, on July

27, 2023, relator submitted a “Sworn Proof of Loss” to Swyfft claiming that his

damages were in the amount of $82,570.91, representing the R. Martinez Consulting

estimate of $99,303.71 less the $15,732.80 deductible called for in the Swyfft policy.

However, as alleged in Allied’s live pleading, on November 2, 2023, Swyfft denied

relator’s claim, concluding that “the damages outlined [in relator’s claim] were

claimed and indemnified with Allied . . . claim number 231254 with date of loss

3/28/23 and reported on 6/20/2023.” According to the facts presented in Allied’s

live pleading, Swyfft further noted that “[o]ther damage was found to be the result

5 of faulty workmanship, age-related wear and tear and deferred maintenance.” After

being made aware of the claim denial, relator sought to initiate the appraisal process

called for in the Swyfft policy. However, the mandamus petition and record provide

no further insight regarding the status of the claim made under the Swyfft policy.

According to Allied’s live pleading, on January 18, 2024, the Dick Law Firm

sent a post-appraisal demand letter to Allied seeking $10,000 in attorney’s fees,

$2,720.60 in interest and approximately $4,402 in “withheld depreciation.” Allied

reportedly responded to the demand letter on March 13, 2024, rejecting the demand

for any further payments to relator. Allied’s live pleading indicates that in its letter,

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In Re David Dick v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-david-dick-v-the-state-of-texas-texapp-2024.