Juan Alvarez v. State Farm Lloyds, 04-17-00251-CV

Alvarez's home sustained wind/hail damage in 2014 and he filed a claim under a State Farm policy.
State Farm initially found damages below the deductible, then after reinspection paid Alvarez $832.57.
Alvarez sued, alleging underpayment and wrongful denial. State Farm invoked the policy's appraisal clause.
Appraisal set loss at $14,377.14; after deductible, prior payment, and depreciation, State Farm paid Alvarez $9,676.62.
State Farm moved for and obtained a take-nothing summary judgment, relying on this court's precedent that payment of an appraisal award bars the insured's contractual and extra-contractual claims. Alvarez appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Menchaca requires reconsideration of Garcia and prevents summary judgment after payment of an appraisal award	Alvarez: Menchaca altered governing law such that Garcia should no longer control	State Farm: Garcia remains controlling; payment of appraisal award entitles insurer to summary judgment absent grounds to set aside award or independent bad-faith injury	Court: Menchaca is distinguishable and does not abrogate Garcia; summary judgment affirmed
Whether payment of an appraisal award bars insured's contract and extra-contractual claims	Alvarez: Appraisal payment does not automatically bar his claims	State Farm: Payment resolves the insured's damages and forecloses contract and bad-faith claims unless appraisal is set aside or insurer committed independent actionable conduct	Court: Payment of the appraisal award entitles insurer to summary judgment where insured offers no basis to set aside the award or evidence of independent injury

Garcia v. State Farm Lloyds, 514 S.W.3d 257 (Tex. App.—San Antonio 2016) (holding an insurer's payment of an appraisal award entitles insurer to summary judgment on insured's contractual and extra-contractual claims)