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

Summary

The Texas Supreme Court held that a third‑party claimant lacks a direct cause of action under Texas Insurance Code art. 21.21, § 16 for unfair claim settlement practices, reversing the appellate court’s reversal of summary judgment and affirming the trial court’s dismissal of that claim. The Court declined to extend the insurer‑insured duties recognized in Vail to third parties. Justice Doggett dissented, and Justice Spector concurred in the judgment but not the reasoning.