Texas Workers' Compensation Insurance Facility v. Peakload Inc. of Bexar County Peakload Personnel Services, Inc. Peakload Inc. of Texas Peakload Inc. of Harris County Peakload Inc. of America Yolanda Canales Dowdy, Individually and in Her Corporate Capacity

CourtCourt of Appeals of Texas
DecidedNovember 19, 1998
Docket03-98-00056-CV
StatusPublished

This text of Texas Workers' Compensation Insurance Facility v. Peakload Inc. of Bexar County Peakload Personnel Services, Inc. Peakload Inc. of Texas Peakload Inc. of Harris County Peakload Inc. of America Yolanda Canales Dowdy, Individually and in Her Corporate Capacity (Texas Workers' Compensation Insurance Facility v. Peakload Inc. of Bexar County Peakload Personnel Services, Inc. Peakload Inc. of Texas Peakload Inc. of Harris County Peakload Inc. of America Yolanda Canales Dowdy, Individually and in Her Corporate Capacity) 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.

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Texas Workers' Compensation Insurance Facility v. Peakload Inc. of Bexar County Peakload Personnel Services, Inc. Peakload Inc. of Texas Peakload Inc. of Harris County Peakload Inc. of America Yolanda Canales Dowdy, Individually and in Her Corporate Capacity, (Tex. Ct. App. 1998).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-98-00056-CV

Texas Workers' Compensation Insurance Facility, Appellant



v.



Peakload Inc. of Bexar County, et al., Appellees



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 98TH JUDICIAL DISTRICT

NO. 96-00513, HONORABLE HUME COFER, JUDGE PRESIDING

The Texas Workers' Compensation Insurance Facility (the "Facility") sued numerous Peakload corporations (1) and individual members of the Dowdy family (2) (collectively "appellees") to recover the difference between the amount of insurance premiums paid by the corporations and the amount claimed to be owing under the Facility's allegations. The Facility appeals from a summary judgment that it take nothing by its claims against appellees. We will affirm the summary judgment.

THE CONTROVERSY

The Facility is a non-profit, unincorporated association of insurers authorized to write workers' compensation insurance in Texas for employers unable to obtain coverage through private insurance companies. (4) These employers are designated "rejected risks." Tex. Ins. Code Ann. art. 5.76-2, § 1.01(10) (West Supp. 1998). The Facility must provide insurance coverage under the statutory scheme for any "risk" (employer) that appears to be "in good faith entitled to insurance." Id. § 4.02(b) (West Supp. 1998). Once the Facility determines that a company is entitled to coverage, the Facility calculates the premium in accordance with classifications and rates established by the Commissioner. (5)

Two factors are used to account for risk in the premium calculation: (1) employees are classified according to risks associated with the work performed; and (2) an employer is rated according to its history of claims filed. Texas Workers' Comp. Ins. v. Personnel Serv., 895 S.W.2d 889, 891 (Tex. App.--Austin 1995, no writ). Employers are assigned an experience modifier based on loss history in order to promote safety and to encourage the filing of fewer claims. An employer with fewer claims receives a credit modifier, namely a multiplier less than 1.0, that reduces the standard premium for workers' compensation insurance. An employer with frequent job-related claims is assigned a multiplier greater than 1.0, or debit modifier, that increases the standard premium. A new business with no loss history is assigned the neutral modifier of 1.0 and pays the standard premium.

Several Peakload corporations obtained workers' compensation insurance from the Facility. (6) Six insurance policies are at issue in this appeal: a policy issued to Peakload Inc., of Bexar County for the period January 16, 1991, through January 16, 1992; two annual policies obtained in the name of Peakload Inc., of Harris County for the period March 14, 1992, to March 14, 1994; and three annual policies obtained in the name of Peakload Personnel Services, Inc., for the period April 15, 1991, to April 15, 1994. Each policy was the subject of a final audit by the Facility's servicing carriers. The Facility concedes the Peakload corporations paid in full the resulting premiums calculated and charged by the Facility.

Believing the various corporations owned by the Dowdy family were mere "shells" used to avoid application of the debit modifiers, by shifting payrolls from corporations with high debit modifiers to newly created Peakload corporations entitled to the standard premium, the Facility brought two causes of action in the present lawsuit: (1) an action for fraud based upon the Dowdys' misrepresentation of the "true nature" of the relationships between the Peakload corporations; and (2) an action for breach of contract based on a theory that the Peakload corporations were in fact and law a single employer and failed to pay premiums calculated on that basis by means of a proper debit modifier. Both causes of action depend upon a common element: the Dowdy family and the Peakload corporations misrepresented the fact that the corporations were, in truth, a single employer or business entity for the purpose of calculating workers' compensation insurance premiums. Because we find the record disproves conclusively this essential element of the Facility's causes of action for fraud and breach of contract, we need not discuss appellees' affirmative defense that the causes of action are barred by the statute of limitations found in section 16.004(a)(3) of the Civil Practice and Remedies Code. (7)

Fraud

In its third point of error, the Facility contends the trial court erred in granting appellees' motion for summary judgment because the summary judgment record raised a genuine issue of material fact concerning whether the Dowdys misrepresented or concealed material facts regarding the true ownership, control, and relationships among the Peakload corporations in order to evade the debit modifier, causing the Facility to provide insurance in excess of the risk for which it received premiums.

The substance of a common-law fraud action is deception as to an existing material fact. Southwestern Bell Tel. Co. v. Meader Constr. Co., 574 S.W.2d 839, 843 (Tex. Civ. App.--El Paso 1978, writ ref'd n.r.e.). The substantive elements are: (1) a material representation, (2) that is false, (3) that the defendant knew was false when made, (4) that was made with the intention that it be acted upon by the other party, (5) that the party acted in reliance on it, and (6) damages. T.O. Stanley Boot Co. v. Bank of El Paso, 847 S.W.2d 218, 222 (Tex. 1992).

In its first amended petition, the Facility alleged six instances of fraudulent conduct, (8) all allegedly motivated by the Dowdys' attempt to conceal that Peakload Inc. was "actually operating as a single employer to intentionally prevent the Facility from acquiring the necessary and material information to compute the proper amount of workers' compensation insurance premiums to charge." (9) The Facility alleged that based upon these misrepresentations, it provided workers' compensation insurance to "the corporate shells of Peakload Inc." at substantially lower premiums than would have been charged had the Facility not been deceived into believing that the "corporate shells" were separate legal entities.

To determine if the record raises an issue of whether the Dowdys defrauded the Facility in the manner alleged, we consider first what constitutes the "employer" (10) when applying for workers' compensation insurance. (11) The Facility contends its method of calculating premiums for workers' compensation insurance is based on evaluating the "entire experience of the . . . employer on all of its operations." The Facility states,



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Texas Workers' Compensation Insurance Facility v. Peakload Inc. of Bexar County Peakload Personnel Services, Inc. Peakload Inc. of Texas Peakload Inc. of Harris County Peakload Inc. of America Yolanda Canales Dowdy, Individually and in Her Corporate Capacity, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-workers-compensation-insurance-facility-v-peakload-inc-of-bexar-texapp-1998.