Travelers Casualty and Surety Company of America v. Steven Wibracht, Erin Wibracht

CourtDistrict Court, W.D. Texas
DecidedDecember 10, 2025
Docket5:20-cv-01433
StatusUnknown

This text of Travelers Casualty and Surety Company of America v. Steven Wibracht, Erin Wibracht (Travelers Casualty and Surety Company of America v. Steven Wibracht, Erin Wibracht) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Travelers Casualty and Surety Company of America v. Steven Wibracht, Erin Wibracht, (W.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS DIVISION

TRAVELERS CASUALTY AND § SURETY COMPANY OF AMERICA, § Plaintiff § § Case No. SA-20-CA-01433-XR v. § § STEVEN WIBRACHT, ERIN § WIBRACHT, § Defendants §

ORDER On this date, the Court considered the status of this case. In particular, the Court considered the amount of damages and attorneys’ fees to be awarded to Third-Party Plaintiff Steven Wibracht. ECF No. 116. BACKGROUND In 2013, Third-Party Plaintiffs Steven Wibracht and Erin Wibracht allegedly contracted to indemnify Plaintiff Travelers Casualty and Surety Company of America (“Travelers”) for losses arising out of Travelers’s issuance of certain bonds (the “Bonds”). ECF No. 1 ¶¶ 9–10. Travelers later demanded that the Wibrachts (and other indemnitors not party to this suit) indemnify it for about $14 million in losses arising from the issuance of the Bonds. Id. ¶¶ 15, 17. The Wibrachts allegedly refused, resulting in this suit. Id. ¶¶ 17–18. Travelers’s claims against the Wibrachts ultimately settled. ECF Nos. 68, 116-1. Meanwhile, the Wibrachts filed a third-party complaint against Michael Padron; Mapco, Inc.; and WPS Group, LLC (the “Third-Party Defendants”). See ECF Nos. 25, 47.1 The Wibrachts

1 The Wibrachts also named James Taylor as a Third-Party Defendant but later dismissed their claims against him with prejudice. See ECF Nos. 107, 111. 1 alleged that, pursuant to certain agreements, these Third-Party Defendants had to indemnify them for Travelers’s claims in this suit and for associated litigation expenses. Id. The Wibrachts also alleged that the Third-Party Defendants had breached a contractual obligation to “use commercially reasonable efforts to promptly secure the release of [the Wibrachts] from their

personal guarantees of” the Bonds (the “Release Provision”). Id. ¶ 51. The Wibrachts moved for summary judgment on their claims against the Third-Party Defendants. ECF No. 85. The Court granted the motion in part and denied it in part. ECF No. 96. It held that the Third-Party Defendants must indemnify Steven for Travelers’s claims in this suit and for associated litigation expenses. See generally id.; see also id. at 9 (noting that the relevant agreement indemnifies Steven for “any ‘claim, litigation, investigation or proceeding . . .’”). It also held that the Third-Party Defendants had breached the Release Provision. Id. at 13–14. But the Court denied summary judgment as to Erin’s claims, finding that the Wibrachts had provided no evidence that Erin was a party to the relevant agreements. Id. at 9. On the Wibrachts’ motion, the Court dismissed Erin’s claims against the Third-Party

Defendants, see ECF Nos. 108, 111, and the parties later dismissed the only remaining claim not resolved on summary judgment. ECF No. 112. The effect of all this is as follows: The remaining parties are Steven and the Third-Party Defendants. The Third-Party Defendants are liable to Steven for their failure to indemnify him and for their failure to “use commercially reasonable efforts to promptly secure” his release from personal guarantees of the Bonds. See ECF No. 96. The remaining issue is how much the Third-Party Defendants owe Steven in damages, attorneys’ fees, and costs. Steven has provided evidence and briefing on this issue. ECF No. 116. The Third-Party Defendants have not, and their deadline to do so has passed. See ECF No. 114.

2 DISCUSSION Steven’s proposed recovery can be split into two primary categories. First, he seeks damages for the Third-Party Defendants’ failure to indemnify him for his settlement and litigation expenses regarding Travelers’s claims. Second, he seeks attorneys’ fees and costs for prosecuting

his failure-to-indemnify claims against the Third-Party Defendants. I. Damages First, Steven seeks damages for the Third-Party Defendants’ failure to indemnify him for his settlement and litigation with Travelers. These damages fall into three categories: (1) what Steven paid to settle the claims, (2) his non-attorney-fee costs to litigate the claims, and (3) his attorneys’ fees for defending against the claims. a. Settlement To start, Steven has provided evidence that he paid $22,000 to settle Travelers’s claims against him. ECF No. 116-1. That evidence is unrebutted, and the Court sees no reason to doubt it, especially because Travelers initially sought the much higher sum of $14 million.

b. Costs Next, Steven has provided unrebutted evidence that to defend against Travelers’s claims he incurred $5,388.30 in non-attorney-fee costs. ECF No. 116-2 at 2; ECF No. 116-4. The Court sees no reason to limit litigation costs recoverable by contract to those available to prevailing parties by statute. See United States ex rel King v. Solvay Pharm., Inc., 871 F.3d 318, 334–35 (5th Cir. 2017) (describing the limits on recoverable costs for prevailing parties). So Steven is entitled to $5,388.30 in non-attorney-fee costs incurred to defend against Travelers’s claims.

3 c. Attorneys’ Fees for Defending Against Travelers’s claims Steven also seeks $41,982.50 in attorneys’ fees expended to defend against Travelers’s claims. To be entitled to attorneys’ fees, even under an indemnity clause, Steven must show that the requested fees are reasonable. Crimson Expl., Inc. v. Intermarket Mgmt., LLC, 341 S.W.3d

432, 446 (Tex. App.—Houston [1st Dist.] 2010, no pet.) (reversing a damages award for breach-of-contract claim based on failure to indemnify for attorneys’ fees, because plaintiff failed to prove the reasonableness of the claimed attorneys’ fees).2 “State law controls . . . the . . . reasonableness of fees awarded where state law supplies the rule of decision.” Keiland Constr., LLC v. Weeks Marine, Inc., 109 F.4th 406, 422 (5th Cir. 2024). Under Texas law, courts generally must use the lodestar method to measure reasonable and necessary attorneys’ fees. Rohrmoos Venture v. UTSW DVA Healthcare, LLP, 578 S.W.3d 469, 497–98 (Tex. 2019) (“[T]he lodestar analysis . . . appl[ies] to any situation in which an objective calculation of reasonable hours worked times a reasonable rate can be employed.”). Under the lodestar test, the “starting point . . . is determining the reasonable hours worked

multiplied by a reasonable hourly rate.” Id. at 498. The party seeking to recover fees “bears the burden of providing sufficient evidence on both counts.” Id. “Sufficient evidence includes, at a minimum, evidence of (1) particular services performed, (2) who performed those services, (3) approximately when the services were performed, (4) the reasonable amount of time required to perform the services, and (5) the reasonable hourly rate for each person performing such services.” Id. The fee agreement between the prevailing party and its attorney is not decisive. Id.

2 One basis for this rule in the contractual-indemnity context could be the principle that someone claiming a breach of contract must “mitigate damages if it can do so with ‘trifling expense or with reasonable exertions,’” Atrium Med. Ctr., LP v. Hou. Red C LLC, 595 S.W.3d 188, 197 n.40 (Tex. 2020) (quoting Gunn Infiniti, Inc. v. O’Byrne, 996 S.W.2d 854, 857 (Tex. 1999)). That is to say, paying unreasonable attorneys’ fees might constitute a failure to mitigate. 4 And “there is a presumption that the base lodestar calculation, when supported by sufficient evidence, reflects the reasonable and necessary attorney’s fees.” Id. Certain considerations can warrant an enhancement or reduction from the lodestar figure. Id. at 499–501.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Travelers Casualty and Surety Company of America v. Steven Wibracht, Erin Wibracht, Counsel Stack Legal Research, https://law.counselstack.com/opinion/travelers-casualty-and-surety-company-of-america-v-steven-wibracht-erin-txwd-2025.