Bernice HUDSPETH, Appellant, v. ENTERPRISE LIFE INSURANCE COMPANY, Appellee, 358 S.W.3d 373

Hudspeth purchased a reducing credit disability insurance policy from Enterprise Life alongside a 2003 Toyota Camry purchase financed through Toyota Motor Credit and Sterling McCall Toyota.
Policy caps its disability benefits as a reducing amount ($33,022 original, 60 months) with remaining coverage valued at $17,410.35 after payments.
Hudspeth filed a disability claim after cancer diagnosed in Sept 2005; Enterprise approved benefits in Dec 2005 but later closed her file in Mar 2006 for failure to submit continuing-claim forms.
Hudspeth struggled to obtain medical verification due to county health services; Enterprise ultimately denied in June 2006 after reviewing April 2006 documents.
Settlements were reached with Toyota Motor Credit and Sterling McCall Toyota, with Enterprise seeking credits/off-sets under the one-satisfaction rule against its contractual liability.
Trial court awarded damages including $1,810.27 after offsets, with appellate remand and partial reversals on several issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Damages cap on contract breach	Hudspeth seeks full car-value damages, not just policy-specified $17,410.35.	Damages are limited to the policy's remaining value ($17,410.35) per contract.	Remanded; cap incorrect; damages recalculated
Offsets under one-satisfaction rule	Offsets should not apply to Enterprise’s contract limit; settlements separate from contract damages.	Offsets apply to prevent double recovery since all claims arise from single injury.	Offsets improperly applied; authorized total damages adjusted to reflect full injury against policy limit
Prejudgment interest calculation	Interest should accrue from 180 days after Enterprise received April 7, 2006 notice with declining-principal treatment for settlements.	Interest begins at different dates; decline formula not clearly appealed.	Remanded for recalculation; 180-day accrual triggered by April 7, 2006 notice; declining-principal formula to be addressed on remand
Accrual and limitations for extra-contractual claims	Claims accrued later; timely under two-year limitations.	Claims accrued on July 5, 2005; limitations barring extracontractual claims.	Extra-contractual claims timely; not time-barred
DTPA claim viability	Policy misrepresented continuation-form requirements and cancellation terms under DTPA.	No misrepresentation; policy clearly required monthly proof; no DTPA violation.	DTPA claims not supported; affirmed as to no misrepresentation

Gross v. Connecticut Gen. Life Ins. Co., 390 S.W.2d 388 (Tex. Civ. App.—El Paso 1965) (contractual damages measure for breach of disability policy)
AMX Enters., Inc. v. Bank One, N.A., 196 S.W.3d 202 (Tex. App.—Houston [1st Dist.] 2006) (one-satisfaction rule scope and application)
Crown Life Ins. Co. v. Casteel, 22 S.W.3d 378 (Tex. 2000) (single injury rule for multiple defendants)
Buccaneer Homes of Alabama, Inc. v. Pelis, 43 S.W.3d 586 (Tex. App.—Houston [1st Dist.] 2001) (one-satisfaction rule applicability to multiple theories)
Johnson & Higgins of Texas, Inc. v. Kenneco Energy, Inc., 962 S.W.2d 507 (Tex. 1998) (accrual standards for contract-based claims)
Brainard v. Trinity Universal Ins. Co., 216 S.W.3d 809 (Tex. 2006) (declining-principal formula for prejudgment interest when settlements are credited)
Battaglia v. Alexander, 177 S.W.3d 893 (Tex. 2005) (settlement credits and prejudgment interest context)
Williams v. United States Fire Ins. Co., 955 S.W.2d 267 (Tex. 1997) (good faith and coverage disputes standard of review)
Viles v. Security Nat’l Ins. Co., 788 S.W.2d 566 (Tex. 1990) (duty to explain policy terms under good-faith standard)
Moriel v. Transp. Ins. Co., 879 S.W.2d 10 (Tex. 1994) (insurer bad-faith standard requires independent tort or reasonable basis for denial)
First Title Co. of Waco v. Garrett, 860 S.W.2d 74 (Tex. 1993) (windfall prevention rationale for one-satisfaction rule)