Pine Oak Builders, Inc., Petitioner v. Great American Lloyds Insurance Company, Respondent

Summary

The Texas Supreme Court held that Pine Oak’s faulty‑workmanship claims are covered as property‑damage occurrences, that the Prompt Payment of Claims statute applies to an insurer’s breach of the duty to defend, that coverage under an occurrence‑based CGL policy is triggered by the actual‑injury rule, and that extrinsic evidence may not be used to expand the insurer’s duty to defend under the eight‑corners rule. Accordingly, the Court affirmed in part and reversed in part the Court of Appeals and remanded for further proceedings.