Westlake Chemical Corporation v. Berkley Regional Insurance Company and Zurich American Insurance Company

CourtCourt of Appeals of Texas
DecidedMay 25, 2023
Docket01-21-00225-CV
StatusPublished

This text of Westlake Chemical Corporation v. Berkley Regional Insurance Company and Zurich American Insurance Company (Westlake Chemical Corporation v. Berkley Regional Insurance Company and Zurich American 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
Westlake Chemical Corporation v. Berkley Regional Insurance Company and Zurich American Insurance Company, (Tex. Ct. App. 2023).

Opinion

Opinion issued May 25, 2023

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-21-00225-CV ——————————— WESTLAKE CHEMICAL CORPORATION, Appellant V. BERKLEY REGIONAL INSURANCE COMPANY AND ZURICH AMERICAN INSURANCE COMPANY, Appellees

On Appeal from the 270th District Court Harris County, Texas Trial Court Case No. 2017-43569

MEMORANDUM OPINION

This appeal involves a commercial insurance coverage dispute. Appellant

Westlake Chemical Corporation tendered claims to Appellees Berkley Regional

Insurance Company and Zurich American Insurance Company seeking coverage for

nearly $16,000,000 in losses resulting from the payment of fraudulent invoices for shipping bags used to export Westlake Chemical Corporation’s products. After a

dispute arose among the parties regarding coverage for the tendered claims,

Westlake Chemical Corporation sued Appellees for breach of contract, violations of

the Texas Insurance Code, and declaratory relief. Appellees counterclaimed for

attorney’s fees. The trial court granted summary judgment in favor of Appellees on

Westlake Chemical Corporation’s claims, and Appellees subsequently nonsuited

their counterclaim for attorney’s fees. This appeal followed.

Westlake Chemical Corporation argues the trial court erred in granting

summary judgment in favor of Appellees. In two issues, Westlake Chemical

Corporation argues the trial court erred by finding that (1) its loss was not covered

by the insurance policy’s computer fraud clause, and (2) the insurance policy

contained an exclusion that barred coverage for its loss.

We affirm the trial court’s judgment.

Background1

Appellant Westlake Chemical Corporation (“Westlake”) manufactures

polyethylene and polyvinyl chloride products, which it sells internationally. From

2007 until 2014, Westlake purchased plastic shipping bags and other supplies to

1 Appellant Westlake Chemical Corporation and Appellees Berkley Regional Insurance Company and Zurich American Insurance Company filed cross-motions for summary judgment and a joint statement of stipulated facts. This background section is based on the parties’ stipulated facts.

2 export its products from John Tinkle (“Tinkle”) through his company Tinkle

Management Inc. (“TMI”), a supplier of shipping bags to chemical companies.2

TMI delivered Westlake’s plastic shipping bags to a warehouse owned by Packwell,

Inc. (“Packwell”), a plastic bagging and logistics company, and Packwell used the

supplies to package and ship Westlake’s chemical products overseas. After the

shipping supplies were delivered by TMI, Tinkle would submit an invoice to

Westlake for payment of the supplies.

From March 2010 until October 2014, Tinkle submitted fraudulent invoices

and supporting documentation to Westlake via email for fictitious bags that were

never delivered to Packwell. Relying on these false invoices and shipping reports,

Westlake paid Tinkle $16,423,941.78 for shipping bags that Tinkle never provided.

Westlake did not discover Tinkle’s fraud until October 23, 2014.

On July 21, 2015, Tinkle was indicted by a federal Grand Jury for fraud and

money laundering. In April 2017, Tinkle pleaded guilty and was sentenced to 48

months in prison and ordered to pay restitution to Westlake in the amount of

$15,633,403.98.

2 During this time, Tinkle also worked as an employee of Packwell, Inc., a plastic bagging and logistics company that provided bagging and shipping services to Westlake.

3 A. Insurance Contracts

Westlake purchased a Commercial Crime Insurance Policy from Appellee

Berkley Regional Insurance Company (“Berkley”) that provided coverage of

$10,000,000 for each occurrence of computer fraud (“Berkley Policy”) and a Crime

Insurance Excess Policy from Appellee Zurich American Insurance Company

(“Zurich,” collectively with Berkley, the “Insurers”) that provided Westlake an

additional $5,000,000 in coverage (“Zurich Policy”).

Berkley Policy

Section A.6 of the Berkley Policy, titled Computer Fraud (“Computer Fraud

Clause”), provides that Berkley

[W]ill pay for loss of or damage to “money”, “securities” and “other property” resulting directly from the use of any computer to fraudulently cause a transfer of that property from inside the “premises” or “banking premises”: a. To a person (other than a “messenger”) outside those premises; or b. To a place outside those “premises”.

Section D.1.c of the Berkley Policy excludes coverage for certain “Acts Of

Employees, Managers, Directors, Trustees Or Representatives.” Section D.1.c

provides that coverage is excluded for

Loss resulting from “theft” or any other dishonest act committed by any of your “employees,” “managers,” directors, trustees or authorized representatives:

Whether acting alone or in collusion with other persons; or

4 While performing services for you or otherwise; except when covered under Insuring Agreement A.1.

The Berkley Policy does not define the terms “computer fraud,” “from the use of

any computer,” or “authorized representative.”

Zurich Policy

The Zurich Policy’s “Insuring Clause” states:

[Zurich] shall provide [Westlake] with insurance coverage during the Policy Period excess of the [Berkley Policy]. Coverage under this policy shall attach only after all of the Limit(s) of Liability of [the Berkley Policy] has been exhausted by the actual payment of loss(es). Except as otherwise provided herein, coverage under this policy shall then apply in conformance with and subject to the warranties, limitations, conditions, provisions, and other terms of the [Berkley Policy] as in effect the first day of the Policy Period, together with the warranties and limitations of [the Berkley Policy]. In no event shall coverage under this policy be broader than coverage under [the Berkley Policy].

After Westlake discovered Tinkle’s fraud in October 2014, Westlake tendered

timely notices of its discovery and Proof of Loss Statements to Berkley and Zurich.

On March 25, 2016, Berkley denied coverage for Westlake’s loss under the Berkley

Policy because the loss did not result directly from the use of a computer and because

it resulted from a dishonest act by an authorized representative of Westlake. The

parties do not dispute that Westlake’s loss is not covered by the Zurich Policy unless

the loss is also covered by the Berkley Policy.

5 B. Procedural History

On June 29, 2017, Westlake sued Berkley for breach of the Berkley Policy

and violations of the Texas Insurance Code. Westlake also sought declaratory

judgment against Zurich as to coverage. Westlake requested attorney’s fees pursuant

to Sections 37.009 and 38.001(8) of the Texas Civil Practice & Remedies Code, and

statutory damages pursuant to Sections 541.152(a)(1) and 542.060(a) of the Texas

Insurance Code. Berkley and Zurich counterclaimed for attorney’s fees.

The Insurers filed a traditional and no-evidence motion for summary

judgment on Westlake’s claims. They argued that Westlake’s losses were not

covered by the Berkley Policy because the policy’s Computer Fraud Clause only

covered losses incurred as a result of computer hacking. They also argued that no

evidence supported Westlake’s extracontractual claims. Westlake cross-moved for

summary judgment on its claims arguing its loss was covered because the Computer

Fraud Clause in the Berkley Policy provides coverage for losses “resulting directly

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Westlake Chemical Corporation v. Berkley Regional Insurance Company and Zurich American Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/westlake-chemical-corporation-v-berkley-regional-insurance-company-and-texapp-2023.