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Vol. 11 - Issue 2

February 28, 2022


At Last: Texas Supreme Court Answers The “Four Corners” Question

Decision Summarized By The Lone Star State’s Go-To Coverage Lawyers


For years, there has been debate in Texas whether, or to what extent, extrinsic evidence can be used to determine if an insurer has a duty to defend.  To put it another way – is the determination of an insurer’s duty to defend limited to the four corners of the complaint?  Countless decisions have addressed this issue.  An answer to the question was in desperate need from the state’s Supreme Court.

At long last it arrived earlier this month in the much-awaited decision in Monroe Guaranty Insurance Co. v. BITCO General Insurance Co.  And the high court wasted no time applying it and providing further guidance.  It did so in Pharr-San Juan-Alamo Independent School District v. Texas Political Subdivisions Property/Casualty Joint Self Insurance Fund, a decision handed down the same day.

When it comes to practicing Texas insurance coverage law, the lawyers at Shidlofsky Law, in Austin, are some of the best in the business [on the policyholder side].  It would be Coverage Opinions malpractice for me to report on these recent decisions without using their detailed summary, and, most importantly – analysis. It can be found here: 





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