State Farm Lloyds/Sheila Fitzgerald and Charles Lanham v. Sheila Fitzgerald and Charles Lanham/State Farm Lloyds

CourtCourt of Appeals of Texas
DecidedAugust 10, 2000
Docket03-99-00177-CV
StatusPublished

This text of State Farm Lloyds/Sheila Fitzgerald and Charles Lanham v. Sheila Fitzgerald and Charles Lanham/State Farm Lloyds (State Farm Lloyds/Sheila Fitzgerald and Charles Lanham v. Sheila Fitzgerald and Charles Lanham/State Farm Lloyds) 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
State Farm Lloyds/Sheila Fitzgerald and Charles Lanham v. Sheila Fitzgerald and Charles Lanham/State Farm Lloyds, (Tex. Ct. App. 2000).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN



NO. 03-99-00177-CV



State Farm Lloyds/Sheila Fitzgerald and Charles Lanham, Appellants



v.



Sheila Fitzgerald and Charles Lanham/State Farm Lloyds, Appellees



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 250TH JUDICIAL DISTRICT

NO. 96-10131, HONORABLE MARY PEARL WILLIAMS, JUDGE PRESIDING



This suit arises out of an insurance claim appellees Sheila Fitzgerald and Charles Lanham filed under their homeowner's policy with appellant State Farm Lloyds ("State Farm"). A jury found State Farm liable for breaching its insurance contract and violating provisions of the Texas Insurance Code and the Deceptive Trade Practices--Consumer Protection Act (the "DTPA"). The trial court rendered judgment on the verdict and awarded appellees $178,284 in damages, along with prejudgment interest and attorney's fees. State Farm appeals in seven points of error. Appellees cross-appeal in one point of error. We will affirm the trial court's judgment.



BACKGROUND



Appellees carry a State Farm homeowner's insurance policy that insures losses up to $137,500. Although the policy generally excludes damages caused by "inherent vice, wear and tear or deterioration . . . or settling, cracking, bulging, shrinkage, or expansion of foundations, walls, or floors," it specifically insures losses caused by accidental discharges of water from a plumbing system. In the event of such losses, State Farm is responsible for paying the reasonable cost of making the necessary repairs. Pursuant to the policy's additional living expenses ("ALE") provision, State Farm must also cover the additional living expenses--including rent, utilities, and moving expenses--that may be incurred should the policyholder's home be rendered uninhabitable.

In October 1994, appellees discovered a plumbing leak in their home. The leak caused extensive damage to the home's walls, hardwood floors, and foundation. Believing that the damage was covered by their homeowner's policy, appellees filed a claim with State Farm. Within one week, State Farm sent an adjuster to the house to evaluate the claim. Initially, the adjuster indicated that the damage was probably not covered by the policy. However, after conducting several tests and inspections, State Farm ultimately concluded four months later in February 1995 that the damages were in fact covered. State Farm agreed to pay for the necessary repairs, which included leveling the home's foundation, rerouting the plumbing, and making several cosmetic repairs.

After learning that the property damage was insured, appellees contacted Lester Germanio, a structural engineer, to draw up a plan of repair. At State Farm's request, appellees also contacted two general contractors of their choice, Robert Coe Builders ("Coe") and Rayco Enterprises ("Rayco"), and solicited bids from both. Coe bid $62,280 on the project. Rayco bid $102,000. Appellees chose to go with the lower estimate submitted by Coe. However, State Farm rejected Coe's bid, claiming that the estimate was too high. Coe agreed to meet with State Farm's adjusters to attempt to settle on a mutually agreeable amount. Ultimately, these negotiations were unsuccessful. At trial, Lanham testified that State Farm's adjuster was abrasive and uncooperative. The adjuster disagreed with several items in Coe's bid, including the amounts allocated for various repairs and the charges Coe included for overhead and profit as a general contractor. In the end, Coe compromised and submitted two revised estimates, but State Farm refused to accept either bid.

In the meantime, appellees vacated their home in anticipation of the construction repairs and rented a nearby house at State Farm's direction. State Farm agreed to pay for appellees' rent, moving expenses, and only a portion of their utility costs in satisfaction of the policy's ALE coverage. In September 1995, almost a year after appellees first filed their claim and approximately seven months after State Farm agreed to pay the claim, appellees received a check from State Farm for $51,888, an amount substantially less than Coe's final bid. Along with the check, State Farm included its own itemized estimate of repairs. According to appellees, this estimate failed to include many items in need of repair. Despite appellees' repeated requests, State Farm refused to take these additional costs into account.

Shortly thereafter, State Farm informed appellees that unless construction began immediately, the ALE coverage would be terminated and appellees would have to move back into the home, regardless of whether any repairs had been made. (1) Both Lanham and Fitzgerald testified that because of the limited amount of time remaining before State Farm would cease paying for their additional living expenses, they felt tremendous pressure to accept State Farm's settlement and find a contractor who could begin work immediately. Fitzgerald searched the yellow pages for any contractor willing to do the job. However, Fitzgerald testified that few contractors would consider doing the work, given the amount of money State Farm had allocated for the project. In the end, only two builders, Capital Construction ("Capital") and Rockwell Builders ("Rockwell"), expressed any interest in doing the repairs. Because Capital was uninsured and lacked any experience doing the type of work required, appellees ultimately were forced to hire Rockwell.

In January 1996, appellees took $28,000 of the funds State Farm had provided and deposited them into a construction account. Rockwell then withdrew $13,000 of this amount and began construction later that same month. Shortly after construction commenced, appellees and Germanio began to question Rockwell's competency. It became apparent that Rockwell was violating many of the specifications in Germanio's plans. Of foremost concern was the fact that the concrete piers Rockwell poured into the ground were only ten feet deep, as opposed to the sixteen feet Germanio had specified. (2) In addition, Rockwell had allowed too much time to lapse between the drilling of the holes and the pouring of the concrete piers. (3) Consequently, every one of the piers Rockwell poured was useless and had to be abandoned, new holes had to be drilled, and new piers had to be constructed using a different technique. In addition to the problems caused by the improperly poured piers, Rockwell damaged much of the home's interior, including the hardwood floors and interior furnishings. At some point, city inspectors "red-tagged" the construction project, effectively halting the repairs because of Rockwell's substandard work. Coe testified that because of the additional work necessary to correct these mistakes, the job became more complicated and expensive than originally anticipated.

Upon discovering these mistakes, appellees immediately fired Rockwell. With no contractor remaining to do the work, insufficient funds to hire a replacement, and no further ALE coverage, appellees felt that they had no choice other than to move back into the home, notwithstanding the unfinished repairs.

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State Farm Lloyds/Sheila Fitzgerald and Charles Lanham v. Sheila Fitzgerald and Charles Lanham/State Farm Lloyds, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-farm-lloydssheila-fitzgerald-and-charles-lan-texapp-2000.