Two Texas Cases That You Need To Know When You Settle Lawsuits Or Claims



Similar documents
Mastering Prejudgment Interest

IS STOWERS A CHANGING?

THE RIGHT TO INDEPENDENT COUNSEL

to add a number of affirmative defenses, including an allegation that Henry s claim was barred

ARKANSAS COURT OF APPEALS

IN THE SUPREME COURT OF TEXAS

Court of Appeals. First District of Texas

Reverse and Render in part; Affirm in part; Opinion Filed December 29, In The Court of Appeals Fifth District of Texas at Dallas

Case 3:07-cv TEM Document 56 Filed 04/27/2009 Page 1 of 12 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION

22 ND ANNUAL COOPER & SCULLY, P.C. INSURANCE SEMINAR

In the Missouri Court of Appeals Eastern District

STATE OF MICHIGAN COURT OF APPEALS

CUNDIFF V. STATE FARM: ALLOWING DOUBLE RECOVERY UNDER UIM COVERAGE

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

No CV IN THE FOR THE RAY ROBINSON,

UNINSURED/UNDERINSURED MOTORIST CLAIMS AFTER BRAINARD. By C. Brooks Schuelke. Perlmutter & Schuelke, LLP th

Liability Insurer s Duty Not to Settle

UNITED STATES COURT OF APPEALS FOR THE TENTH CIRCUIT ORDER AND JUDGMENT * After examining the briefs and appellate record, this panel has determined

COURT OF APPEALS OF WISCONSIN PUBLISHED OPINION

IN THE SUPREME COURT, STATE OF WYOMING 2011 WY 109

VIRGINIA ACTS OF ASSEMBLY SESSION

Case 1:10-cv CCB Document 28 Filed 03/05/12 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

Prepared by Jeff Suess, Kevin Schnurbusch and Debbie Champion of the firm Rynearson, Suess, Schnurbusch & Champion, L.L.C.

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF JACKSON COUNTY ) ) BETTY CHRISTY, ) ) ) )

Fourth Court of Appeals San Antonio, Texas

2015 IL App (3d) U. Order filed February 5, 2015 IN THE APPELLATE COURT OF ILLINOIS THIRD DISTRICT A.D., 2015

THE TEXAS PROMPT PAYMENT OF CLAIMS STATUTE AND ITS APPLICATION TO THE DUTY TO DEFEND

Commonwealth of Kentucky Court of Appeals

Court of Appeals. First District of Texas

MASSACHUSETTS INSURANCE LAW UPDATE

Case Alert. Midtown Medical Group, Inc. v. Farmers Insurance Group Arizona Court of Appeals, July 15, 2014

INSURANCE AND MISSOURI LAW

REVERSE, RENDER, and REMAND; and Opinion Filed August 20, In The Court of Appeals Fifth District of Texas at Dallas. No.

The tort of bad faith failure to pay or investigate is still an often plead claim by

SECTION PERFORMANCE BOND., hereinafter called PRINCIPAL, and

Recent Case Update. Insurance Stacking UIM Westra v. State Farm Mutual Automobile Insurance Company (Court of Appeals, 13 AP 48, June 18, 2013)

JUDGMENT AFFIRMED. Division II Opinion by JUDGE TERRY Casebolt and Furman, JJ., concur. Announced June 10, 2010

In The NO CV. HARRIS COUNTY, Appellant. JOHNNY NASH, Appellee

NUMBER CV COURT OF APPEALS THIRTEENTH DISTRICT OF TEXAS

HEADNOTE: Kevin Mooney, et ux. v. University System of Maryland, No. 302, Sept. Term, 2007 SECURED TRANSACTIONS SOVEREIGN IMMUNITY

IN THE SUPREME COURT OF TEXAS

ADDRESSING MEDICAL LIENS IN AUTO ACCIDENT LITIGATION. Jonathan R. Granade. Casey Gilson P.C.

REVERSE, RENDER, REMAND, and AFFIRM; and Opinion Filed August 22, In The Court of Appeals Fifth District of Texas at Dallas. No.

ORDER GRANTING TRAVELERS INSURANCE COMPANY / HARTFORD UNDERWRITERS INSURANCE S MOTION TO INTERVENE

IN THE SUPREME COURT OF TEXAS

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

2015 IL App (5th) U NO IN THE APPELLATE COURT OF ILLINOIS FIFTH DISTRICT

Theda Spurgeon Appellant Vs. No CV -- Appeal from Erath County Coan & Elliott, Attorneys at Law Appellee

The Enforceability of Mediated Settlement Agreements. By: Thomas J. Smith The Law Offices of Thomas J. Smith San Antonio, Texas

IN THE SUPREME COURT OF TEXAS

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

Performance Bond. Business):

2005-C CHARLES ALBERT AND DENISE ALBERT v. FARM BUREAU INSURANCE COMPANY, ET AL. (Parish of Lafayette)

CODING: Words stricken are deletions; words underlined are additions. hb

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION EIGHT

IN THE COURT OF APPEALS OF TENNESSEE AT JACKSON. TALMAGE CRUMP v. KIMBERLY BELL

IN COURT OF APPEALS DECISION DATED AND FILED

Commonwealth of Kentucky Court of Appeals

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

IN THE COURT OF APPEALS OF INDIANA

IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT. No Non-Argument Calendar. Docket No. 1:13-cv WSD.

Submit a Valid Claim Form Deadline: February 12, 2016 Ask to be excluded Deadline: November 24, Object Deadline: November 24, 2015

In the Missouri Court of Appeals Eastern District

Supreme Court of Missouri en banc

THE THREAT OF BAD FAITH LITIGATION ETHICAL HANDLING OF CLAIMS AND GOOD FAITH SETTLEMENT PRACTICES. By Craig R. White

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

S13G1048. CARTER v. PROGRESSIVE MOUNTAIN INSURANCE. This Court granted a writ of certiorari to the Court of Appeals in Carter

APPEAL FROM THE CIRCUIT COURT OF LACLEDE COUNTY. Honorable G. Stanley Moore, Circuit Judge

2015 IL App (2d) U No Order filed December 24, 2015 IN THE APPELLATE COURT OF ILLINOIS SECOND DISTRICT

SUPREME COURT OF MISSOURI en banc

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

THE STATE OF FLORIDA...

Kentucky Department of Education Version of Document A

Debt Claim Petition Packet

NEW YORK NY GENERAL OBLIGATIONS LAW TITLE 17 STRUCTURED SETTLEMENT PROTECTION ACT

MEMORANDUM OPINION. REVERSE and RENI)ER; Opinion Filed April 1, In The Qoitrt of Appeah3 li1rici of xu at ki11a. No.

INSURANCE COVERAGE HOW TO GET PAID. Henry Moore Advanced Personal Injury - State Bar of Texas

Fourteenth Court of Appeals

Before the recent passage of CRS , claims for subrogation

STATE OF MICHIGAN COURT OF APPEALS

GAIL EDWARDS a/k/a GAIL RAFIANI, Chapter 13 Case No.: Debtor. GAIL EDWARDS a/k/a GAIL RAFFIANI, Plaintiff, v. Adversary No.

STATE OF MICHIGAN COURT OF APPEALS

In The Court of Appeals Fifth District of Texas at Dallas. No CV

MEDIATION RELEASE AND SETTLEMENT AGREEMENT ISSUES IN CONSTRUCTION CASES by Benton T. Wheatley

Transcription:

Two Texas Cases That You Need To Know When You Settle Lawsuits Or Claims Lauren Pierce Cooper & Scully, P.C. 900 Jackson Street, Suite 100 Dallas, Texas 75202 Tel: 214-712-9539 Email: lauren.pierce@cooperscully.com 2015 This paper and/or presentation provides information on general eral legal issues. It is not intended to provide advice on any specific legal matter or factual situation, and should not be construed as defining Cooper r and Scully, P.C.'s position in a particular situation. Each casec must be evaluated on its own facts. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Readers should not act on this information without receiving professional legal counsel.

Two Texas Cases That You Need To Know When You Settle Lawsuits Or Claims McAllen Hospitals v. State Farm Mut.. Ins. Co. of Tex., 433 S.W.3d 535 (Tex. May 16, 2014). Viewpoint Bank v. Allied Prop. & Cas.. Ins. Co.,, 439 S.W.3d 626 (Tex. App. - Dallas 2014, pet. filed).

Type Of Lien In McAllen Hospitals: Statutory Hospital Lien Provides hospital additional method for securing payment for treatment to accident victims. Hospital has lien on cause of action of accident victim (and related settlement or judgment) for cost of treatment if victim admitted within 72 hours of accident. Hospital must comply with notice and recording requirements to perfect lien.

Notice and Filing Requirements Ensure that All Parties Know About Lien To secure the lien, health care provider must: 1. Provide notice to the injured individual that lien was filed within 5 days after receiving notice that lien has been recorded by county; and 2. File written notice of lien with county clerk of county in which services were provided, before money is paid to injured person. (Tex. Prop. Code Section 55.005)

Facts of McAllen Hospitals 2 people injured in a car wreck caused by a State Farm insured; Each injured person received medical treatment from McAllen Medical Center; Hospital perfected a statutory lien for medical bills; State Farm, aware of lien, settled with injured persons; Releases signed and executed, checks delivered to injured persons payable to injured person and hospital as co- payees; Injured persons only endorsed and cashed checks, didn t pay McAllen Medical Center; and McAllen Medical Center sued State Farm for amount of liens.

Did Delivery of Settlement Check to Claimant Discharge the Lien? One of these things must happen to release the lien (Tex. Prop. Code 55.007): 1. The charges of the provider were paid in full before the execution and delivery of the release (NO); 2. The provider is a party to the release (NO); or 3. The charges were paid before the execution and delivery of the release to the extent of any full and true consideration paid to the injured individual by or on behalf of the other parties to the release (??). State Farm: By issuing to claimant and hospital as co-payees, made good faith effort to pay to extent of full and true consideration paid. Hospital:

Analysis under the UCC Since State Farm wrote checks to satisfy its underlying obligations, the Supreme Court applied the UCC to resolve the issue. Supreme Court overruled, in part, Dallas Court of Appeals holding in Benchmark Bank v. State Farm, 893 S.W.2d 649 (Tex. App. Dallas 1994, no writ). Agreed with Benchmark that delivery of check to one co-payee is constructive delivery to the other co-payee. Disagreed with Benchmark s holding that obligation is discharged after check is honored and paid even if wrongly paid.

Why Did the Court Disagree with Benchmark? Under UCC, check is paid to the extent payment is made by a party obliged to pay the check and to a person entitled to enforce the check.. (UCC 3.602(a)) When check is issued to two non-alternative co- payees, one co-payee acting alone is not entitled to enforce the check.. (UCC 3.110(d)) Check to co-payees is payable to all and may be negotiated, discharged or enforced only by all of them. Followed Massachusetts Supreme Court reasoning (check jointly payable to insured and vehicle lienholder).

Remedies Hospital could have sued payor bank, but that did not affect State Farm s s obligations under the check. Under Section 55.007, when lien is not properly paid out of proceeds of patient s s settlement, the release is invalid, cause of action is revived, and hospital retains lien on cause of action. But: : this does not mean hospital has right to recover from payor (insurer). So does it?

Supreme Court Punted (Sort of) Court held issue of whether hospital could enforce revived lien against State Farm was not preserved for appeal, and thus would not decide the issue. Court noted that Hospital Lien Statute expressly specifies the remedy for failure to properly satisfy a hospital lien (cause of action is not released) but does not create cause of action against third parties (like an insurer) to enforce the lien. Calls into question holding in Baylor Univ. Med. Center v. Borders,, 581 S.W.2d 731 (Tex. App. Dallas 1979, writ ref d n.r.e.).) which held statute gives hospital such a claim against third parties.

The Takeaway from McAllen Hospitals Writing one check jointly to claimant and plaintiff s s counsel and entrusting counsel to pay health care liens will not suffice to discharge lien. Merely including indemnity language, in which claimant guarantees payment and indemnifies insurer, does not suffice to discharge lien (and won t t help if the claimant has spent the money and is judgment-proof). Court specifically noted that State Farm delivered the checks without notifying hospital. Would the result change if State Farm had notified the hospital?

Along comes Viewpoint Bank Hurricane Ike property damage claim; Optimum owned property, Viewpoint Bank held mortgage and was loss payee under policy; Allied, the insurer, paid the claim by tendering (to Optimum) checks jointly payable to Optimum and Viewpoint. Optimum...

Viewpoint Sued Allied Trial court granted summary judgment in favor of Allied, relying on Benchmark Bank s holding that was overruled in McAllen Hospitals,, and denied Viewpoint s s summary judgment motion. Dallas court of appeals, citing McAllen Hospitals, held summary judgment in favor of Allied was in error. Allied has filed petition for review. Court rejected Allied s s argument that this rule should be applied only prospectively, but Allied raised this issue again in petition for review.

Viewpoint Claimed it was Entitled to Summary Judgment under UCC Viewpoint claimed it should recover against Allied under the UCC as a matter of law. Different situation than McAllen Hospitals because Viewpoint was a loss payee under the insurance policy, but that is not basis of holding. Court held that under UCC, Viewpoint was entitled to enforce check against Allied. Allied s s remedy was against bank that improperly deposited/paid the checks. *Allied has filed petition for review. Court followed precedent from other states Supreme Court relied on in McAllen Hospitals.

Safest Practice after McAllen Hospitals and Viewpoint Bank Find out during investigation of claim or suit if there is a hospital or other lien (such as landlord s s lien, child support lien) via discovery, property records, UCC-1 1 filings. Be aware of loss payees under policy. Reach agreement prior to settlement as to how much goes to lienholder/loss payee, and make separate checks part of settlement; or Condition settlement on lien-holder/loss payee signing release that allows for payment of check to plaintiff s attorney and plaintiff, with indemnity language that plaintiff promises to pay lien-holder/loss payee and will indemnify insurer.

Food for Thought Practically speaking, how often will one co-payee cash settlement check and fail to pay other co-payee? Consider cost of changing long-standing practices in paying settlements v. risk. Also there should still be remedy against the bank. What if mortgagee s s only interest is in ensuring that property is repaired with proceeds, but expects no payment? What happens if insurer settles a property damage claim in suit or after initial claim payment, where bad faith claims are asserted? Is insurer required to put the mortgagee on check? What about auto wreck with personal injury and property damage claim where plaintiff wants to characterize settlement as only property damage?

More Food for Thought If insurer holds onto the check or waits to ask for a check to be cut given unresolved co-payee situation, does insurer risk violating the Texas Prompt Pay Statute? Tex. Ins. Code Section 542.058(a): if an insurer after receiving all items reasonably requested and required under Section 542.055,, delays payment of the claim,, the insurer shall pay damages.