Joseph Johnson v. State Farm Lloyds

Texas Court of Appeals, 3rd District (Austin)·Decided March 26, 2026·No. 03-24-00314-CV·Published

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-24-00314-CV

Joseph Johnson, Appellant v.

State Farm Lloyds, Appellee

FROM THE 421ST DISTRICT COURT OF CALDWELL COUNTY NO. 19-O-004, THE HONORABLE CHRIS SCHNEIDER, JUDGE PRESIDING

MEMORANDUM OPINION

Joseph Johnson appeals a summary judgment rendered in favor of State Farm Lloyds on his claims for violations of Chapters 541 and 542 of the Texas Insurance Code and breach of a renter’s insurance policy covering personal property stored in an airport hangar. We will affirm in part and reverse and remand in part.

BACKGROUND

Johnson was the insured under a renter’s insurance policy issued by State Farm.

Johnson operated a skydiving business and stored his business and personal equipment in rented space in a hangar at an airport. The hangar that Johnson rented is a common area shared by several tenants. Johnson’s insurance policy provided that it covered “physical loss to property” caused by certain “perils,” one of which was defined as “[t]heft, including attempted theft and loss of property from a known location when it is probable that the property has been stolen.”

The contract further provided, however, that the covered theft “peril” did not include “loss caused by theft committed by an insured.” In September 2017, Johnson reported a theft loss to State Farm. He informed State Farm that parachutes and tools given to him by his father had been stolen from the hangar. 1 After conducting an investigation, State Farm ultimately denied Johnson’s claim.

In January 2019, Johnson sued State Farm alleging violations of the Texas Insurance Code. Johnson asserted that State Farm was required to “reasonably and promptly” investigate his claim and promptly pay his claim once liability was “reasonably clear.” In support of his claims, Johnson alleged that he was the victim of a robbery in September 2017; that State Farm’s investigation was insufficient; and that State Farm determined, without any evidentiary basis, that Johnson had “somehow staged the robbery for purposes of filing a fraudulent claim.” Johnson alleged that there was no dispute that a theft had occurred; that the stolen property at issue was covered by the policy; and that there was “no evidence whatsoever to support the theory that [he] staged the robbery.” Johnson also asserted a claim for breach of contract, alleging that State Farm breached the renter’s insurance policy by refusing to pay for a covered loss.

After conducting discovery, State Farm moved for summary judgment. State Farm asserted that there were “major discrepancies in [Johnson’s] story” and that “multiple witnesses testified that [Johnson] staged the theft and [Johnson] was still in possession of the allegedly stolen items after reporting the theft.” State Farm argued that this information created a bona fide dispute about its liability under the policy that provided a reasonable basis to

1 In his deposition, Johnson testified that the stolen parachutes were his personal property and that a number of other parachutes owned by his skydiving business were not stolen. Johnson’s renter’s insurance policy covered only Johnson’s personal property.

withhold payment of the claim and that the existence of the bona fide dispute conclusively established that its liability under the policy was not “reasonably clear.” Regarding Johnson’s breach of contract claim, State Farm asserted that Johnson disclaimed having knowledge of what tools were actually stolen and that, consequently, there was no evidence of the value of the covered loss.

After a hearing, the trial court granted State Farm’s motion for summary judgment and rendered judgment a take-nothing judgment against Johnson. This appeal followed.

DISCUSSION

We review the granting of a motion for summary judgment de novo. 2 When the trial court does not specify the grounds for its ruling, summary judgment must be affirmed if any of the grounds on which judgment was sought are meritorious. State v. Ninety Thousand Two Hundred Thirty-Five Dollars & No Cents ($90,235) in U.S. Currency, 390 S.W.3d 289, 292 (Tex. 2013).

Extracontractual Claims Johnson alleges extracontractual (tort) damages arising from State Farm’s alleged violation of the Texas Insurance Code. An insurer will not be liable for extracontractual damages, either under the common law or pursuant to a statute, based on its having challenged a

2 The standards for reviewing a summary judgment are well established and undisputed on appeal. See, e.g., City of Keller v. Wilson, 168 S.W.3d 802, 827 (Tex. 2005); see also Goodyear Tire & Rubber Co. v. Mayes, 236 S.W.3d 754, 755 (Tex. 2007); Fort Worth Osteopathic Hosp., Inc. v. Reese, 148 S.W.3d 94, 99 (Tex. 2004); Ford Motor Co. v. Ridgway, 135 S.W.3d 598, 600 (Tex. 2004); see also Tex. R. Civ. P. 166a(c), (i). Accordingly, we need not repeat them here.

claim of coverage if there was a reasonable basis for its denial of that coverage. See Republic Ins. v. Stoker, 903 S.W.2d 338, 340 (Tex. 1995) (if insurers have reasonable basis for their denial of coverage, they retain right to deny questionable claims without being exposed to extracontractual damages, even if denial of coverage is later determined to have been erroneous); Lyons v. Millers Cas. Ins. Co. of Tex., 866 S.W.2d 597, 601) (Tex. 1993) (applying same analysis to both common-law and statutory bad faith claim); Emmert v. Progressive Cnty. Mut. Ins., 882 S.W.2d 32, 37 (Tex. App.—Tyler 1994, writ denied) (statutory claims require same predicate for recovery as common-law bad faith causes of action).

In a bad faith case, the plaintiff has the burden to prove that the insurance company had no reasonable basis for denying the claim. Transportation Ins. v. Moriel, 879 S.W.2d 10, 18 (Tex. 1994). The insured’s evidence must relate to the tort issue of no reasonable basis for denial, not just to the contractual issue of coverage. Lyons, 866 S.W.2d at 601. “The focus on the evidence and its relation to the elements of bad faith is necessary to maintain the distinction between a contract claim on the policy and a claim of bad faith delay or denial of that claim, which arises from the tort duty we imposed on insurers in Arnold and Aranda.” Id. at 600 (citing generally Aranda v. Insurance Co. of N. Am., 748 S.W.2d 210 (Tex. 1998) overruled on other grounds by Texas Mut. Ins. v. Ruttiger, 381 S.W.3d 430 (Tex. 2012); Arnold v. National Cnty. Mut. Fire Ins., 725 S.W.2d 165 (Tex. 1987)). “Evidence that merely shows a bona fide dispute about the insurer’s liability on the contract does not rise to the level of bad faith.” Transportation Ins., 879 S.W.2d at 18. An insurer cannot, as a matter of law, be liable for bad faith insurance practices if it had a reasonable basis to withhold payment. See State Farm Lloyds, Inc. v. Polasek, 847 S.W.2d 279, 285 (Tex. App.—San Antonio 1992, writ denied) (“[I]f a reasonable basis exists for questioning the insurance claim, the insurer may deny

it and litigate the matter without also facing a bad faith claim.”). A bona fide dispute about the insurer’s liability on the insurance contract supplies that reasonable basis. Thus, we consider whether State Farm’s summary-judgment evidence demonstrated the existence of a bona fide dispute about whether the property loss for which Johnson sought payment was excluded from coverage because it was a loss caused by theft committed by Johnson.

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