Texas Mutual Insurance Co. v. Ruttiger
381 S.W.3d 430
| Tex. | 2012Background
- 1989 Texas Workers’ Compensation Act reforms modernized dispute resolution, benefits calculation, and added ombudsman support; core issue is interaction with Insurance Code and DTPA and whether Aranda duty survives.
- Court overruled Aranda and held no common-law bad-faith claim against a workers’ comp carrier under current Act.
- Ruttiger sued Texas Mutual Insurance Co. for Insurance Code, DTPA, and common-law bad-faith claims based on delays in temporary income benefits and surgery coverage.
- BRC/WCD dispute resolution occurred; parties executed a binding benefit-dispute agreement approved by the WCD.
- Court held Ruttiger exhausted administrative remedies via the BRC agreement and WCD approval, giving trial court jurisdiction to hear the claims.
- Court reversed appellate judgment and rendered for TMIC, finding Insurance Code claims and Aranda-based common-law claim no longer viable under the amended Act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ruttiger exhausted administrative remedies to give the court jurisdiction | Ruttiger exhausted remedies via BRC/Agreement | TMIC argues exhaustion required WCD determination | Jurisdiction proper; exhaustion satisfied by binding BRC agreement and WCD approval |
| Whether Insurance Code claims can supplement workers’ compensation remedies | Marshall allows Insurance Code claims against carriers | Act’s detailed scheme precludes extra-contractual claims | Insurance Code claims (541.060/541.061/542.003) not viable alongside amended Act; overrules Marshall on this point |
| Whether DTPA claims can survive without Insurance Code support | DTPA claims rely on Insurance Code violations | Without viable Insurance Code claims, DTPA fails | DTPA claims cannot survive where Insurance Code claims fail |
| Whether Aranda duty of good faith survives under the current Act | Aranda duty remains viable despite reforms | Act’s Chapter 416 and reforms abrogate Aranda-type claims | Aranda duty overruled; no extra-statutory common-law bad faith claim against carriers under current Act |
| Whether the jury’s damages for common-law/insurance claims are supportable | Damages sustain independent injury from bad-faith processing | Remedies align with Act’s procedures; independent injury insufficient | No viable Insurance Code or common-law bad-faith damages; judgment for plaintiff reversed |
Key Cases Cited
- Aranda v. Insurance Co. of North America, 748 S.W.2d 210 (Tex.1988) (held Aranda duty extendable to workers’ compensation carrier (overruled))
- Aetna Cas. & Sur. Co. v. Marshall, 724 S.W.2d 770 (Tex.1987) (held Insurance Code claims against carriers possible before modern Act)
- Lopez v. City of Waco, 259 S.W.3d 147 (Tex.2008) (an exclusive remedy analysis; specific vs. general statutes framework)
- Waffle House, Inc. v. Williams, 313 S.W.3d 796 (Tex.2010) (limits on applying common-law remedies within regulatory schemes)