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TIG Insurance Co. v. Sedgwick James of Washington

The terms of an insurance policy may not be reformed without some proof that the party with the power to do so shared an antecedent understanding.

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Appeal from the United States District Court for the Southern District of Texas

The district court dismissed TIG Insurance Co. (“TIG”) and Safety Lights Sales & Leasing Co.’s (“Safety Lights”) claims to recover for the costs of defending a lawsuit; the insurance seller’s certificate of insurance added Safety Lights as an additional insured but disclaimed the power to alter an underlying insurance policy. The parties agree that the certificate of insurance’s express limitations combine with the policy’s terms to bar coverage contractually. Agreeing with the district court that TIG and Safety Lights also failed to provide summary judgment evidence sufficient to support claims for estoppel, mutual mistake, fraudulent misrepresentation, or negligent misrepresentation, we affirm.

I.

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