Cases

Bafo v. Progressive County Mutual Insurance Co.

Court

ND Tx

Publish Date

04/01/2026
A court of the Northern District of Texas granted an insurer’s motion to dismiss and for summary judgment in a third-party auto liability insurance dispute, holding that an injured third-party claimant lacked standing to sue the insurer directly for policy benefits absent a judgment against the insured and could not maintain extra-contractual claims, because Texas’s no-direct-action rule barred the suit and the insurer made no actionable promise or independent duty to the claimant.
auto liability policy, no-direct-action rule, no direct action rule, third-party claimant, standing, FRCP 12(b)(6)