Glenn Hegar, Comptroller of Public Accounts of the State of Texas and Ken Paxton, Attorney General of the State of Texas v. Health Care Service Corporation, 652 S.W.3d 39

Health Care Service Corporation (Blue Cross) sold stop-loss policies to self-insured employers in Texas; these reimburse employers for employee health-care costs exceeding individual or aggregate "points of attachment."
In 2012 Blue Cross received $171.6 million in stop-loss premiums and paid premium and maintenance taxes; it later sought a refund.
Comptroller assessed taxes under Tex. Ins. Code ch. 222 (premium tax, 1.75%) and ch. 257 (maintenance tax) on those premiums.
Blue Cross sued for refund, arguing stop-loss policies do not "cover risks on individuals or groups" and are not "health insurance." Trial court and court of appeals ruled for Blue Cross; Comptroller appealed.
The Supreme Court reviewed whether (1) stop-loss premiums cover "risks on individuals or groups" and (2) they "arise from the business of . . . health insurance" (and thus are subject to chs. 222 and 257).

Issue	Plaintiff's Argument (Blue Cross)	Defendant's Argument (Comptroller)	Held
Do stop-loss policies "cover risks on individuals or groups" under §222.002(b)?	Policies insure the employer (a juridical entity), not natural persons or groups of persons.	Policies reimburse based on individual and aggregate employee claims, so they hedge risks on individuals and groups.	Court: Taxable — stop-loss policies cover risks on individuals and groups.
Do the premiums "arise from the business of . . . health insurance" for §222 purposes?	Stop-loss is not "health insurance" as defined in Chapter 1201; it is distinct from direct health insurance.	Stop-loss limits employer liability for employee health-care costs and directly relates to health-insurance obligations.	Court: Taxable — premiums arise from the business of health insurance.
Are stop-loss premiums subject to the Chapter 257 maintenance tax?	Stop-loss covers losses to employers, not bodily injury/sickness to natural persons; not every Blue Cross product is within maintenance-tax scope.	Stop-loss is administratively regulated as health insurance; Blue Cross is authorized to write it under its health insurance authority.	Court: Taxable — treated and regulated as health insurance and subject to maintenance tax.

Tex. Dep’t of Ins. v. Am. Nat’l Ins. Co., 410 S.W.3d 843 (Tex. 2012) (endorsing State’s regulatory classification of stop-loss as direct health insurance for administrative purposes)
TracFone Wireless, Inc. v. Comm’n on State Emergency Commc’ns, 397 S.W.3d 173 (Tex. 2013) (tax statutes construed against taxing authority when ambiguous)
Lockheed Martin Corp. v. Hegar, 601 S.W.3d 769 (Tex. 2020) (taxpayer bears burden of proving refund entitlement; de novo statutory interpretation)
Unigard Sec. Ins. Co. v. Schaefer, 572 S.W.2d 303 (Tex. 1978) (when legislature enumerates exceptions, courts generally decline to add others)
Kroger Co. v. Keng, 23 S.W.3d 347 (Tex. 2000) (repeals by implication are disfavored)
Beeman v. Livingston, 468 S.W.3d 534 (Tex. 2015) (canon of consistent usage: same word given consistent meaning throughout statute)