in Re Liberty Mutual Insurance Company, Arch Insurance Company and Speciality Adjusters, Inc.

CourtCourt of Appeals of Texas
DecidedFebruary 24, 2009
Docket14-09-00086-CV
StatusPublished

This text of in Re Liberty Mutual Insurance Company, Arch Insurance Company and Speciality Adjusters, Inc. (in Re Liberty Mutual Insurance Company, Arch Insurance Company and Speciality Adjusters, Inc.) 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 Liberty Mutual Insurance Company, Arch Insurance Company and Speciality Adjusters, Inc., (Tex. Ct. App. 2009).

Opinion

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed February 24, 2009

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed February 24, 2009.

In The

Fourteenth Court of Appeals

____________

NO. 14-09-00086-CV

IN RE LIBERTY MUTUAL INSURANCE COMPANY, ARCH INSURANCE COMPANY, and SPECIALTY ADJUSTERS, INC., Relators

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

M E M O R A N D U M   O P I N I O N

In this original proceeding, relators, Liberty Mutual Insurance Company, Arch Insurance Company, and Specialty Adjusters, Inc., seek a writ of mandamus ordering the respondent, the Honorable Patricia Hancock, presiding judge of the 113th District Court of Harris County, to set aside her order of December 15, 2008, granting the motion for protection filed by real party in interest, Gulf Atlantic Operations, Inc. (AGAO@).  We conditionally grant the writ. 


                                                               Background

On August 29, 2005, Hurricane Katrina struck the Gulf Coast, flooding major portions of GAO=s asphalt refinery and terminals located in Chickasaw, Alabama.  On September 13, 2006, relators denied GAO=s Hurricane Katrina-related losses in excess of $5 million.  On June 7, 2007, GAO sued relators alleging they had (1) wrongfully denied coverage under their respective policies for GAO=s losses from Hurricane Katrina above a $5 million policy sub-limit, and (2) acted in bad faith by failing to conduct a reasonable investigation of GAO=s claims, and by failing to effectuate a prompt, fair, and equitable settlement of GAO=s claims after liability had become reasonably clear.[1]  GAO seeks to recover for property damage, business interruption losses, professional fees, and other consequential damages. 


On October 6, 2008, GAO filed a motion for partial summary judgment contending relators, as a matter of law, had breached their respective policies by denying GAO=s Katrina losses in excess of $5 million.  At issue in the summary judgment proceeding was whether GAO=s property, located in AFlood Zone AE,@ is subject to the $5 million sub-limits in the policies Ain respect of Flood Zones >A= and >V.=@  The term AFlood Zones@ refers to a classification system developed by Federal Emergency Management Agency (AFEMA@)for the purpose of determining property insurance coverage.  Under the FEMA system, land areas have been divided into different zones reflecting FEMA=s determination of flooding risk and severity in those areas.  Relators responded to GAO=s motion with the contention that the only reasonable construction of the sub-limit of A$5,000,000 per occurrence . . . in respect of Flood Zones >A@ and >V=@ is that it applies to all AA@ flood zones, including Flood Zone AE; therefore, the policies= $5 million flood sub-limit applies to all flood losses sustained by GAO at properties located in Flood Zone AE. 

On November 12, 2008, the trial court granted GAO=s motion for partial summary judgment, finding, as a matter of law:  (1) relators had breached their respective insurance policies by denying GAO=s claims for losses related to Hurricane Katrina that were in excess of $5 million; (2) the $5 million sub-limit Ain respect of Flood Zones >A= and >V=@ in the policies does not apply to any of GAO=s Hurricane Katrina-losses; and (3) the $5 million sub-limit Ain respect of Flood Zones >A= >V=@ does not apply to GAO=s claims for business interruption losses, professional fees or non-flood property losses.  GAO=s bad faith and tort claims are still pending. 

Beginning in September 2008, relators issued a number of third-party subpoenas and requests for documents related to GAO=s understanding of the flood zone designations at the time it acquired the insurance on the subject properties and the subsequent negotiation of the sub-limit.[2]  On November 21 and 24, 2008, GAO requested that relators withdraw each of the third-party document requests to eliminate this Anon-relevant discovery.@ 


On November 26, 2008, relators filed a motion for reconsideration and clarification, requesting that the trial court suspend its partial summary judgment ruling and rehear the issues after adequate discovery had been completed, and argued that the limited amount of evidence strongly suggests GAO knew the Flood Zone sub-limit applied to its properties.  Relators further argued Athe expectations and understanding of the scope of coverage of the parties and their brokers is clearly relevant to whether the Insurers acted in good faith,@ and alternatively requested that the trial court allow discovery on the intentions and understandings of the parties with respect to the scope of the coverage because it is relevant to relators= defense of GAO=s bad faith allegation.  On December 15, 2008, the trial court denied relators= motion for reconsideration and clarification. 

On December 9, 2008, GAO filed a motion for a protective order requesting that the trial court strike relators=

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in Re Liberty Mutual Insurance Company, Arch Insurance Company and Speciality Adjusters, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-liberty-mutual-insurance-company-arch-insura-texapp-2009.