Weingarten Realty Management Company and Scottsdale Insurance Company v. Liberty Mutual Fire Insurance Company

CourtCourt of Appeals of Texas
DecidedMay 26, 2011
Docket14-09-00860-CV
StatusPublished

This text of Weingarten Realty Management Company and Scottsdale Insurance Company v. Liberty Mutual Fire Insurance Company (Weingarten Realty Management Company and Scottsdale Insurance Company v. Liberty Mutual Fire Insurance Company) 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
Weingarten Realty Management Company and Scottsdale Insurance Company v. Liberty Mutual Fire Insurance Company, (Tex. Ct. App. 2011).

Opinion

Affirmed and Majority and Dissenting Opinions filed May 26, 2011.

In The

Fourteenth Court of Appeals

___________________

NO. 14-09-00860-CV

Weingarten Realty Management Company and Scottsdale Insurance Company, Appellants

V.

Liberty Mutual Fire Insurance Company, Appellee

On Appeal from the 151st District Court

Harris County, Texas

Trial Court Cause No. 2006-70622

DISSENTING OPINION

Under Texas law, the eight-corners rule is used to determine whether an insurer has a duty to defend.  The Supreme Court of Texas has never recognized an exception to this rule, and in several cases, our high court has pronounced that if it were ever to recognize an exception to this rule it would do so only within a very narrow set of circumstances.  Under these cases, this court may not recognize an exception to the eight-corners rule outside the context specified by the Supreme Court of Texas.  Because the case under review does not fit within this context, the majority errs in recognizing an exception to this important rule of Texas jurisprudence.

General Principles of the Eight-Corners Rule

            In determining a duty to defend, Texas courts follow the eight-corners rule, also known as the complaint-allegation rule: “‘an insurer’s duty to defend is determined by the third-party plaintiff’s pleadings, considered in light of the policy provisions, without regard to the truth or falsity of those allegations.’”  Zurich American Ins. Co. v. Nokia, Inc., 268 S.W.3d 487, 491 (Tex. 2008) (quoting GuideOne Elite Ins. Co v. Fielder Road Baptist Church, 197 S.W.3d 305, 308 (Tex. 2006)).  Thus, “‘[e]ven if the allegations are groundless, false, or fraudulent the insurer is obligated to defend.’”  Id. (quoting 14 Couch on Insurance § 200:19).  We resolve all doubts regarding the duty to defend in favor of the existence of a duty, and we construe the pleadings liberally.  Id.  If the petition does not contain factual allegations sufficient to clearly bring the underlying case within or without the coverage, the general rule is that the insurer is obligated to defend if, potentially, there is a case under the petition within the coverage of the policy.  Id.  The duty to defend is not affected by facts ascertained before suit or developed in the course of litigation, or by the ultimate outcome of the suit.  Id.  If a petition potentially includes a covered claim, the insurer must defend the entire suit.  Id

            Despite various requests over the years to recognize exceptions to the eight-corners rule, the Supreme Court of Texas has never done so.[1] See Pine Oak Builders, Inc. v. Great Am. Lloys Ins. Co., 279 S.W.3d 650, 654–56 (Tex. 2009).  Though, as explained below, our high court discussed in GuideOne the possibility of recognizing an exception to this rule, it did not do so, and our high court has continued to emphasize the importance of adherence to the eight-corners rule.  See Burlington Northern and Santa Fe Ry. Co. v. Nat’l Union Fire Ins. Co. of Pittsburgh, 334 S.W.3d 217, 219 (Tex. 2011) (stating that “the determination as to duty to defend is according to the eight-corners rule wherein only the pleadings and the policy language are considered”); D.R. Horton-Texas Ltd. v. Markel Int’l Ins. Co., 300 S.W.3d 740, 744 (Tex. 2009) (stating that the “analysis of the duty to defend has been strictly circumscribed by the eight-corners doctrine”); Nokia, Inc., 268 S.W.3d at 497 (stating that “while Maryland has recognized exceptions, in some limited circumstances, to the eight-corners rule, Texas has not”) (quotations omitted); GuideOne Elite Ins. Co., 197 S.W.3d at 308–11 (discussing possibility of adopting exception to eight-corners rule); King v. Dallas Fire Ins. Co., 85 S.W.3d 185, 187 (Tex. 2002) (stating that “[a]n insurer’s duty to defend is determined solely by the allegations in the pleadings and the language of the insurance policy”).

Judicial Dicta as to Any Potential Exception to the Eight-Corners Rule

            In GuideOne, the Supreme Court of Texas held that it would not recognize an exception to the eight-corners rule under the circumstances of that case, which are not the same circumstance as those in the case under review.  See GuideOne Elite Ins. Co., 197 S.W.3d at 308–11.  Nonetheless, beyond this holding, the GuideOne court made deliberate statements for future guidance in the conduct of litigation.  See Edwards v. Kaye, 9 S.W.3d 310, 314 (Tex. App.—Houston [14th Dist.] 1999, pet. denied).  These statements are judicial dicta binding on this court.  See id

            According to the United States Court of Appeals for the Fifth Circuit, the teaching of GuideOne is that, though the Supreme Court of Texas may never recognize an exception to the eight-corners rule, if it were to recognize an exception, it would do so only in the narrow circumstance in which “‘it is initially impossible to discern whether coverage is potentially implicated and when the extrinsic evidence goes solely to a fundamental issue of coverage which does not overlap with the merits of or engage the truth or falsity of any facts alleged in the underlying case.’” Liberty Mut. Ins. Co. v. Graham, 473 F.3d 596, 600–601 (5th Cir. 2006) (quoting GuideOne Elite Ins. Co., 197 S.W.3d at 309, and applying Texas law).  After the Fifth Circuit decided Graham, the Supreme Court of Texas, in the Nokia case, embraced this characterization of GuideOneSee Nokia, Inc., 268 S.W.3d at 497–98.  The Nokia court described the foregoing narrow situation in which an exception to the eight-corners rule might be recognized.  See id. at 497.  The court then concluded that, even if the extrinsic evidence in Nokia

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Related

Liberty Mutual Insurance v. Graham
473 F.3d 596 (Fifth Circuit, 2006)
Guideone Elite Insurance Co. v. Fielder Road Baptist Church
197 S.W.3d 305 (Texas Supreme Court, 2006)
Pine Oak Builders, Inc. v. Great American Lloyds Insurance Co.
279 S.W.3d 650 (Texas Supreme Court, 2009)
D.R. Horton-Texas Ltd. v. Markel International Insurance Co.
300 S.W.3d 740 (Texas Supreme Court, 2009)
Zurich American Insurance Co. v. Nokia, Inc.
268 S.W.3d 487 (Texas Supreme Court, 2008)
Centeq Realty, Inc. v. Siegler
899 S.W.2d 195 (Texas Supreme Court, 1995)
King v. Dallas Fire Insurance Co.
85 S.W.3d 185 (Texas Supreme Court, 2002)
Blue Ridge Insurance v. Hanover Insurance
748 F. Supp. 470 (N.D. Texas, 1990)
Accufleet, Inc. v. Hartford Fire Insurance Co.
322 S.W.3d 264 (Court of Appeals of Texas, 2010)
Edwards v. Kaye
9 S.W.3d 310 (Court of Appeals of Texas, 2000)
Liberty Mutual Insurance v. Graham
407 F. Supp. 2d 808 (N.D. Texas, 2005)
Exxon Corp. v. Tidwell
867 S.W.2d 19 (Texas Supreme Court, 1993)

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Weingarten Realty Management Company and Scottsdale Insurance Company v. Liberty Mutual Fire Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/weingarten-realty-management-company-and-scottsdal-texapp-2011.