Lambert v. State Farm Lloyds
The court found that the insurer's prompt payment of an appraisal award precluded insureds' common law and statutory bad faith claims because they had not pleaded or proved an independent injury but found that their claim for prompt payment penalties was viable and so remanded the case to the trial court for a determination of whether the insurer had violated the Texas Prompt Payment of Claims Act.
homeowner's insurance policy, Prompt Payment of Claims Act, TPPCA, independent injury, bad faith, appraisal, extracontractual, payment deadline, timely payment
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