State Farm Fire & Casualty Company, Petitioner v. James and Cynthia Simmons, Respondents

Summary

The Texas Supreme Court affirmed the appellate court's judgment that State Farm breached its duty of good faith and fair dealing, but reversed the $2 million punitive damages award and ordered additional damages under the Deceptive Trade Practice‑Consumer Protection Act. The Court held that evidence of a biased, pretextual investigation was legally sufficient for bad‑faith liability, while finding the record insufficient to support punitive damages. Justice Hecht and Justice Enoch dissented, arguing that the evidence did not meet the objective element of bad faith.