In Frank v. Bradshaw, 920 S.W.2d 699 (Tex. App.--Houston 1st Dist. 1996, no writ), an insurance adjuster allegedly made representations to Frank, the victim of a motor vehicle accident, that there was no time problem with regard to her claim.
He allegedly promised Frank that, after the treatment was finished and all of her medical bills were received, he would pay her claim.
After the insurance adjuster had received several medical bills from Frank, he sent a letter informing Frank that the statute of limitations had passed and that he would not pay any more claims or expenses. Id.
The First Court of Appeals found these representations by the insurance adjuster were sufficient to create a question of fact on equitable estoppel and to avoid summary judgment. Id.