Celtic Life Insurance Company, Petitioner v. John D. Coats, Jr., Respondent

Summary

The Texas Supreme Court held that Celtic Life Insurance is liable for its agent's misrepresentations made within the scope of authority, that reliance is not a required element of DTPA recovery, and that treble damages are unavailable where the misrepresentation was not made knowingly. The Court affirmed the lower courts' judgment but removed the award of trebled damages. Justice ENOCH dissented, arguing liability should be limited to non‑absurd interpretations, while Chief Justice Phillips concurred, emphasizing the distinction between vicarious liability and contractual modification.