Vada De Jongh v. State Farm Lloyds, Inc., 664 F. App'x 405

In April 2012 a storm damaged De Jongh’s home; she filed a claim with State Farm in May 2012. An initial adjuster inspected and concluded covered storm damage was absent; some problems were attributed to maintenance.
State Farm’s internal notes (June 11–12, 2012) show intent to deny; State Farm closed the claim file on July 12, 2012 without paying and (according to its records) intending to send a denial letter that De Jongh says she never received.
De Jongh requested a reinspection on August 17, 2012; State Farm reopened the file and reinspected August 23, 2012, found minor damage below the deductible, and sent a denial/declination letter on August 23 (which De Jongh alleges was the only denial she received).
De Jongh initially sued related entities in November 2012; procedural issues led to vacatur and remand. She amended to name State Farm on July 14, 2014.
State Farm moved for summary judgment arguing accrual occurred when it first closed the claim (July 12, 2012), making De Jongh’s July 14, 2014 suit time-barred under the policy’s 2-year limitation (and Texas statutes for extra-contractual claims). The district court granted summary judgment; the Fifth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When did De Jongh’s cause of action accrue?	Accrual occurred on August 23, 2012 when State Farm sent the only denial letter she received after reinspection.	Accrual occurred on July 12, 2012 when State Farm first closed the claim file (an effective denial).	Accrued on July 12, 2012 when State Farm closed the file; limitations began then.
Does reopening/reinspection reset the limitations period?	Reinspection and later denial restarted or tolled the limitations period.	Reinspection does not reset the accrual date; a later denial after final closure doesn’t restart limitations.	Reinspection did not restart the clock; limitations ran from initial closure.
Is claim-file closure without contemporaneous mailed denial a legally effective denial?	Failure to send the earlier denial letter undermines the claim that an effective denial occurred in July.	Closing the file was an objectively verifiable act showing final denial, regardless of mailing failure.	File closure constitutes an unambiguous final determination and triggers accrual even if a denial letter wasn’t mailed.
Was summary judgment appropriate on accrual/limitations?	Factual disputes (e.g., which denial letter plaintiff received) precluded summary judgment.	No genuine dispute on the operative fact: State Farm closed the claim on July 12, 2012.	Summary judgment proper because accrual date was a legal consequence of undisputed file closure.

Provident Life & Accident Ins. Co. v. Knott, 128 S.W.3d 211 (Tex. 2003) (accrual rule for first-party insurance claims; insurer denial triggers accrual)
Murray v. San Jacinto Agency, Inc., 800 S.W.2d 826 (Tex. 1990) (cause of action accrues when insurer denies claim; accrual timing guidance)
Kuzniar v. State Farm Lloyds, 52 S.W.3d 759 (Tex. App.—San Antonio 2001) (claim-file closure held to be an objectively verifiable denial triggering accrual)
Pace v. Travelers Lloyds of Texas Ins. Co., 162 S.W.3d 632 (Tex. App.—Houston [14th Dist.] 2005) (reconsideration/second denial does not necessarily restart limitations)
Martin Res. Mgmt. Corp. v. AXIS Ins. Co., 803 F.3d 766 (5th Cir. 2015) (standard of review for summary judgment in Fifth Circuit)