In Ben Bolt-Palito Blanco Consol. Indep. Sch. Dist. v. Tex. Political Subdiv. Prop. Cas. Joint Self-Ins. Fund, 212 S.W.3d 320 (Tex. 2006), ninety-two governmental entities formed an insurance fund to provide casualty insurance to fund participants. See 212 S.W.3d at 322. Fund members elected a governing board, and a board subcommittee resolved self-insurance claim disputes. See id. at 327. The Fund argued that its immunity from suit was not waived by local government code section 271.152 because no goods or services were provided to the Fund under the insurance contract with a member entity. See id. Disagreeing, the supreme court held that the Fund's immunity from suit was waived because the members provided services to the Fund in that the members elected the governing board whose subcommittee resolved claim disputes. See id. Thus, in Ben Bolt, even though the service provided to the Fund was not the primary purpose of the contract, the members' provision of claim dispute services was sufficient to fall within the waiver of immunity under local government code section 271.152. See id. at 327-28. The Court took an expansive view of Tex. Loc. Gov't Code section 271.152 in determining that in it the Legislature provided a clear and unambiguous waiver of the local governmental entity's immunity from suit as to the contract in question. See Ben Bolt, 212 S.W.3d at 326-27. In that case, a school district filed a declaratory-judgment action against a self-insurance fund composed of ninety-two local governmental entities. See id. at 322. The school district sought a declaration that a loss it had sustained was a "covered occurrence" under its insurance policy with the fund. See id. at 323. The fund asserted governmental immunity. See id. After determining that the fund enjoyed governmental immunity in its own right, the Texas Supreme Court addressed whether, in section 271.152, the Legislature had waived the fund's immunity from suit as to the declaratory-judgment action in question. See id. at 327. The fund asserted that the agreement at issue in the case -- the insurance policy -- did not involve the provision of goods or services to the fund because the school district was simply paying the fund for insurance coverage. See id. at 324-26. Nonetheless, the Ben Bolt court rejected this argument based on the fund's admission that its members, including the school district in question, elect a governing board, a subcommittee of which resolves claims disputes. See id. The Ben Bolt court concluded that, by participating in the election of the fund's governing board, the school district provided services to the fund, and the high court found that this provision of services satisfied the statutory requirement of "a written contract stating the essential terms of the agreement for providing goods or services to the local governmental entity." See id. The Ben Bolt court reached this conclusion without requiring that this provision of services by the members of the fund be stated in the agreement (the insurance policy). Even though the essence of the agreement (insurance policy) appeared to be an insurance transaction in which the only thing provided to the fund was money, the Ben Bolt court concluded that the agreement fell within the scope of the statutory language because the school district was a member of the fund and the fund's members elected the fund's governing board. "To this extent, at least, the Fund's members provide services to the Fund." Id. at 327. The Ben Bolt court acknowledged that, under section 271.152, the Legislature has not waived immunity as to all contracts entered into by local government entities; rather, it has waived immunity only as to written contracts "stating the essential terms of the agreement for providing goods or services to the local governmental entity that are properly executed on behalf of the local governmental entity." TEX. LOC. GOV'T CODE 271.151(2); Ben Bolt, 212 S.W.3d at 326-27. Nonetheless, the Ben Bolt court broadly construed the meaning of this statutory language. See Ben Bolt, 212 S.W.3d at 326-27.