Elephant Insurance Company, LLC v. Lorraine Kenyon, Individually and as Executrix of the Estate of Theodore Kenyon

Elephant Insurance · Supreme Court of Texas · April 22, 2022 · No. No. 20-0366

Summary

Justice Evan A. Young, joined by Justice Blacklock, concurs in the Texas Supreme Court’s judgment but argues that the Court should reconsider its approach to recognizing new common-law tort duties. The concurrence emphasizes the judiciary’s limited lawmaking role in highly regulated areas, including automobile-insurance claims processing, and suggests that courts should defer to comprehensive statutory and regulatory schemes.

Questions Presented

  1. Whether Texas courts should reconsider their framework for recognizing new common-law duties in negligence cases, particularly the practice of weighing social, economic, political, and related policy considerations.
  2. Whether the existence of comprehensive statutory and regulatory schemes should cause courts to refrain from creating or retain­ing extra-statutory tort duties in highly regulated contexts such as automobile-insurance claims processing.

Disposition

other

Cases Cited (14)

  • In re State, 602 S.W.3d 549 (Tex. 2020)(followed for proposition)
  • Chambers-Liberty Counties Navigation District v. State, 575 S.W.3d 339 (Tex. 2019)(followed for proposition)
  • Archer v. Anderson, 556 S.W.3d 228 (Tex. 2018)(followed for proposition)
  • Morath v. The Texas Taxpayer & Student Fairness Coalition, 490 S.W.3d 826 (Tex. 2016)(followed for proposition)
  • Strickland v. Medlen, 397 S.W.3d 184 (Tex. 2013)(followed for proposition)
  • Texas Mutual Insurance Co. v. Ruttiger, 381 S.W.3d 430 (Tex. 2012)(followed)
  • Aranda v. Insurance Co. of North America, 748 S.W.2d 210 (Tex. 1988)(overruled)
  • Arnold v. National County Mutual Fire Insurance Co., 725 S.W.2d 165 (Tex. 1987)(followed as historical foundation)
  • Pagayon v. Exxon Mobil Corp., 536 S.W.3d 499 (Tex. 2017)(followed as existing precedent)
  • Humble Sand & Gravel, Inc. v. Gomez, 146 S.W.3d 170 (Tex. 2004)(followed as existing precedent)

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