Allstate Insurance Co. v. Watson
In Allstate Insurance Co. v. Watson, 876 S.W.2d 145 (Tex. 1994), the plaintiff was injured in a car accident with Allstate's insured and sued Allstate under Article 21.21, section 16 for failing to attempt in good faith to effectuate a prompt settlement of her claims, although the insured's liability had been reasonably established. Id. at 146.
The Court denied standing because allowing third-party claimants standing to sue an insurer for unfair claims settlement practices would directly conflict with the well-established duties insurers owe their insureds. See id. at 150.
Among these duties, an insurer must defend its insured against the claims asserted by a third party. Watson, 876 S.W.2d at 150.
But the claimant in Watson asked us to extend these same duties to a party adverse to the insured. Watson, 876 S.W.2d at 147.
Allowing third parties a direct cause of action, we determined, would create situations in which an insurer would be exposed to potential liability by these conflicting duties. Watson, 876 S.W.2d at 150.