Christopher Hall v. Germania Farm Mutual Insurance Association, 07-16-00304-CV

May 2013 storm damages Hall's insured property; Germania adjusted, valued net claim around $13,000.
Germania tendered two checks totaling about $9,700, then ~$1,200 after adjustments; Hall rejected.
Hall sued Germania in 2014 for breach of contract, Prompt Pay Act, Insurance Code, and DTPA.
Germania demanded appraisal in Oct. 2014; appraisal concluded Feb. 12, 2016 valuing loss at $31,497.
Germania paid $18,566.32 on Feb. 24, 2016, with counsel conditioning payment on Hall's dismissal of suit.
Trial court granted summary judgment for Germania; court of appeals reversed on estoppel and extra-contractual claims and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Estoppel defense based on appraisal payment timing	Hall: payment within reasonable time not proven; estoppel not established	Germania: tender within reasonable time; estoppel should bar contract claims	Partly sustained; material facts about payment timing unresolved; estoppel not proven as a matter of law
Extra-contractual claims viability after contract estoppel	Hall: extra-contractual claims survive if contract claims survive	Germania: without contract breach, no extra-contractual claims	Remanded; summary judgment reversed to permit record development on extra-contractual claims

State Farm Lloyds v. Johnson, 290 S.W.3d 886 (Tex. 2009) (enforceability of appraisal clauses; time to pay not strictly defined by clause)
Hennessey v. Vanguard Ins. Co., 895 S.W.2d 794 (Tex. App.—Amarillo 1995) (estoppel as an affirmative contract-based defense; requires proof of elements)
Garcia v. State Farm Lloyds, 514 S.W.3d 257 (Tex. App.—San Antonio 2016) (appraisal as binding; estoppel considerations)
Moore v. Dilworth, 179 S.W.2d 942 (Tex. 1944) (implied reasonable time for payment when not specified)
Cross Timbers Oil Co. v. Exxon Corp., 22 S.W.3d 24 (Tex. App.—Amarillo 2000) (cannot rewrite contract to fix provisions not included)
Scottish Union & Nat’l Ins. Co. v. Clancy, 8 S.W. 630 (Tex. 1888) (appraisal results binding; damages calculated per contract)