Allstate Insurance Company, Petitioner v. Kathleen G. Watson, Respondent

Summary

The Texas Supreme Court held that a third‑party claimant does not have a direct cause of action under Texas Insurance Code art. 21.21, § 16 for unfair claim settlement practices, reversing the Court of Appeals on that issue and affirming the trial court’s summary judgment. The Court based its decision on a strict reading of the statute’s exclusive list, legislative history, and the limitation of Vail to insureds.