Aranda v. Insurance Co. of North America
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Supreme Court of Texas overruled Aranda’s common-law claim against workers’ compensation carriers in Texas Mutual Insurance Co. v. Ruttiger; an earlier appellate decision had declined to extend Aranda to a self-insured municipality.
57 later cases cite Aranda v. Insurance Co. of North America; 57 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Aranda v. Insurance Co. of North America?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled
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The Supreme Court of Texas overruled Aranda’s common-law claim for breach of the duty of good faith and fair dealing against a workers’ compensation carrier.
Texas Mutual Insurance Co. v. Ruttiger · Supreme Court of Texas · filed
We also overrule Aranda, 748 S.W.2d 210. We hold that an injured employee may not assert a common-law claim for breach of the duty of good faith and fair dealing against a workers’ compensation carrier.
Read the full opinion on CourtListener →
Limited
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The court declined to extend Aranda’s good-faith duty to a self-insured municipality because governmental immunity barred the employee’s claim.
Jackson v. City of Galveston · Court of Appeals of Texas, Fourteenth District, Houston · filed
Jackson argues the reasoning in Aranda is no less compelling when the employer is a self-insured municipality. The Legislature, however, has seen fit to shield a municipality from tort liability when the city is performing a “governmental” rather than a “proprietary” function.
Read the full opinion on CourtListener →
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