The insured’s bad faith claims failed as the court found that the insurer’s handling of the claim was reasonable. Terrazas v. State Farm Lloyds, 2025 U.S. Dist. LEXIS 201925 (W.D. Tex. Oct. 20. 2025).

Plaintiff filed a claim with State Farm when her home suffered hail damage. Claims Specialist Denice Gomez was assigned to inspect, but she was unable to access the roof. She inspected the interior of the home and found water damage and observed hail damage on the garage doors. Ms. Gomez retained SeekNow to complete the roof inspection.

SeekNow found only minor hail damage to some of the roof tiles. Based on this inspection, State Farm estimated a net cash value payment of $1,329.73. Plaintiff disagreed and State Farm revised its assessment to a net payment of $3,280.54. Payment was also made for damaged personal property in the amount of $4,723.71.

Plaintiff was still unsatisfied and demanded payment of $236,911.73, claiming the damage to the roof was extensive and the roof material was no longer produced, meanng the entire roof had to be replaced.

State Farm retained Roof Consulting Network as a causation and damages expert. The experts found very minor hail damage. They determined that the construction and architecture of the home as well as the lack of roof maintenance was to blame for much of the damage to the roof.

Plaintiff sued for breach of contract and bad faith, State Farm moved for partial summary judgment on the bad faith claim.

Under Texas law, a cause of action for bad faith existed when the insurer had no reasonable basis for denying or delaying payment of a claim. Here, plaintiff offered nothing more than conclusory allegations that State Farm’s inspection of the roof was unreasonable because its inspector did not access the roof but instead retained a third-party to inspect te roof. State Farm, however, retained SeekNow who found only minor hail damage. Further, State Farm retained experts who concluded that there was very minor storm-related damage and a full roof replacement was unneccesary.

Plaintiff offered no evidence to support the claim that a reasonble insurer would have acted differently and instead sought to rest simply on the claims that Ms. Gomez did not get on the roof and that SeekNow was not a permissible substitute. State Farm’s motion was granted.