Fifth Circuit Affirms in Schnatzmeyer v. State Farm Lloyds: 2021 Water-Damage Claims Held Time-Barred
The U.S. Court of Appeals for the Fifth Circuit issued an unpublished opinion on October 22 in Schnatzmeyer v. State Farm Lloyds, No. 25-11369. A residential property owned by Mark Schnatzmeyer and Carole Sandlin in Dallas, Texas, sustained water damage on February 17, 2021, when a neighbor's frozen pipes burst during a freeze. State Farm Lloyds issued its estimate and claim decision on March 12, 2021, paid the insureds $4,261.52, and closed the claim. The property was damaged again on December 24, 2022, when the insureds' own pipes burst in another freeze; after further exchanges with the insurer, the insureds sued on November 3, 2023.
A panel of Circuit Judges Stewart, Richman and Higginson held, in a per curiam opinion, that the claims related to the 2021 claim are time-barred. The policy's contractual limitations period of two years and one day began to run on State Farm's March 12, 2021 determination, and the insurer's later reconsideration of additional information did not restart the clock, because State Farm never withdrew or changed its initial decision. The insureds' bad faith, misrepresentation, fraud and conspiracy claims, and their claim under the Texas Prompt Payment of Claims Act, were likewise barred or forfeited. The court therefore affirmed the summary judgment granted to State Farm by the U.S. District Court for the Northern District of Texas. (GSM, based on the October 22 opinion of the U.S. Court of Appeals for the Fifth Circuit)
Published by GSM · USA (original Chinese edition)
Photo: 图：Dallas 市中心天际线（2023 年资料图）。照片：Emmanuelope，CC0，经 Wikimedia Commons。 / Downtown Dallas skyline (2023 file photo). Photo: Emmanuelope, CC0, via Wikimedia Commons.
