Mangine v. State Farm Lloyds

In Mangine v. State Farm Lloyds, 73 S.W.3d 467, 468 (Tex. App.-Dallas 2002, pet. denied), the insured made a claim under their homeowner's insurance policy for alleged hail damage to their roof. In affirming the trial court's summary judgment based on a statute of limitations defense, the Fifth District court of appeals decided that the adjuster's completed building estimate form, stating that the adjuster found no evidence of hail damage, "conveyed in writing State Farm's determination with respect to the insureds' claim for hail damage and the reasons for it," even though the writing did not use the word "denial." Id. at 471. The court ultimately concluded that although an insurer's denial of a claim must be in writing, "there are no magic words that must be used to deny a claim." Id.