Jerry, Marsha and Jason Chambers v. Allstate Insurance Company
05-14-00065-CV
| Tex. App. | Feb 5, 2015Background
- July 2008 crash between Chambers and Allstate insured; Allstate at fault alleged.
- Allstate offered to settle property damage for $8,321 and take the motorcycle; Chambers accepted but title transfer stalled and funds unpaid.
- Chambers sued asserting oral contracts to pay property damage and medical expenses; negotiations produced a “Partial Release” and nonsuits.
- Chambers signed and returned the release by email; later claimed page 3.5 created a two-agreement scenario and absence of meeting of the minds.
- Trial court held a hearing on enforcement, severed claims against Allstate, and later issued a final order; Chambers amended pleadings to assert promissory estoppel regarding medical expenses; appeal followed.
- Court reverses in part and remands; promissory estoppel claim regarding medical expenses to be reconsidered; other aspects affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of the property-damage settlement | Chambers: no meeting of minds; page 3.5 incomplete. | Allstate: release contained essential terms and was a complete agreement; Allstate performed. | Enforceable contract; release valid. |
| Promissory estoppel regarding medical expenses | Promissory estoppel not addressed; seek relief. | Medical expenses promissory estoppel not properly pled or addressed. | Issues sustained; final order incomplete; remand for promissory estoppel on medical expenses. |
| Finality and incorporation of prior rulings in severed case | Final order improperly altered or re-decided prior claims. | Final order properly summarized prior rulings and resolved severed case. | Issues resolved against Chambers; final order proper in core aspects. |
| DTPA 17.46(b)(12) no-evidence challenge | Chambers challenged no-evidence ruling on DTPA claim. | Record insufficient to raise fact issue on challenged DTPA elements. | Issue 1 (DTPA) resolved against Chambers; no error found. |
Key Cases Cited
- Padilla v. LaFrance, 907 S.W.2d 454 (Tex. 1995) (proper enforcement mechanisms for settlement agreements; meeting of minds not satisfied means contract may be enforced as contract)
- Lehmann v. Har-Con Corp., 39 S.W.3d 191 (Tex. 2001) (judgment final but erroneous may require reversal; finality considerations)
- Principal Life Ins. Co. v. Revalen Dev., LLC, 358 S.W.3d 451 (Tex. App.—Dallas 2012) (contract formation requires complete and definite essential terms; meeting of minds)
- Wheeler v. White, 398 S.W.2d 93 (Tex. 1965) (promissory estoppel distinguished from breach of contract)
- In re C.H.C., 396 S.W.3d 33 (Tex. App.—Dallas 2013) (discussion of meeting of minds and contract formation)