Here is a Summary of State Farm Mut. Auto. Ins. Co. v. Lance Bellis, No. 14-24-00468-CV (Tex. App. — 14th Dist.) (Mem. Op. filed Nov. 13, 2025). You can read the full text of the opinion by clicking here.
What happened (facts & procedural posture)
In August 2019 Bellis’s truck collided with a vehicle driven by Victor Pedraza Jr.; Bellis alleged a new left-shoulder injury that ultimately required surgery. Bellis sued the tortfeasor and also pursued a UIM (underinsured-motorist) claim against his insurer, State Farm. After Bellis settled with the tortfeasor for that driver’s limits, the case proceeded against State Farm. A jury found Pedraza 100% at fault and awarded Bellis $210,000.01 in damages. The trial court entered judgment ordering State Farm to pay Bellis $100,000 (the UIM limit) plus prejudgment and post-judgment interest (at 5.5%), and denied Bellis’s request for attorney’s fees. State Farm appealed; Bellis cross-appealed the denial of fees.
Jury breakdown & trial judgment numbers
• Total jury award: $210,000.01.
• Itemized awards (per record): $70,000 (past lost earning capacity), $64,687.50 (future lost earning capacity), $18,510.65 (past medical expenses).
• UIM policy limit: $100,000; trial court ordered payment of that limit plus prejudgment/post-judgment interest.
Appellate court decision
The Fourteenth Court of Appeals affirmed the trial court’s judgment as modified — it removed the award of prejudgment interest but otherwise affirmed: the court held the evidence supporting the challenged damage awards was legally and factually sufficient, and the trial court did not abuse its discretion in denying attorney’s fees. The memorandum opinion was filed November 13, 2025.
Analysis
1. Sufficiency of the evidence (claims State Farm raised)
State Farm argued the medical evidence did not prove the 2019 accident caused a new shoulder injury (because Bellis had a prior shoulder injury in 2011). The appellate court applied the usual legal- and factual-sufficiency standards and emphasized the jury’s role as factfinder. The court relied on treating clinicians’ testimony — especially Dr. Masson (the surgeon) — who testified the surgical findings showed a “massive” rotator cuff tear that was not consistent with a decade-old, unrepaired tear and that, within reasonable medical probability, the 2019 crash caused the injury. Because reasonable jurors could accept that expert testimony and the other evidence, the court concluded the evidence was both legally and factually sufficient to support the awarded past/future lost earning capacity and past medical expenses. In short: credibility and causation disputes were for the jury and the record supported the jury’s verdict.
Practical takeaways: where a plaintiff has preexisting conditions, clear expert testimony explaining why the current injury is new/different is decisive; appellate courts will defer to reasonable jury credibility evaluations.
2. Prejudgment interest
The opinion walks through the Texas law distinctions between (a) Cavnar/§304.102 prejudgment interest (interest an insured could recover from a tortfeasor) and (b) Henson-type interest (prejudgment interest recoverable from an insurer on top of policy benefits when the insurer breached). Because the jury award exceeded the UIM policy limits ($210k award vs. $100k policy), Cavnar-type interest against the tortfeasor would not translate into additional recoverable interest from the insurer beyond policy limits (per Brainard and related authorities). That left only Henson-type interest as a possible basis — but Henson-type interest requires a record showing the insurer withheld policy benefits (i.e., evidence the insurer breached or failed to tender). The court found the record silent as to whether State Farm had tendered the policy limits (or otherwise breached), so it could not sustain the trial court’s independent award of prejudgment interest against State Farm. The appellate court therefore deleted the prejudgment interest award.
Practical takeaways: awarding prejudgment interest on top of UIM benefits is legally delicate in Texas; when a jury award exceeds UIM limits the insurer’s exposure to prejudgment interest is constrained and depends on whether the insurer breached a contractual obligation to pay. Absent evidence of tender/breach the insurer may successfully challenge extra interest.
3. Attorney’s fees (cross-appeal)
Bellis claimed the trial court erred by denying attorney’s fees under his UDJA/declaratory judgment claim. The appellate panel agreed the reasonableness/necessity of fees are fact questions for a factfinder; here, the parties had agreed not to submit the fees question to the jury during the first phase, and Bellis failed to present or preserve the facts needed to support a fees award in that phase. Because the fees issue was not submitted or proved at the liability trial and Bellis accepted those procedural limits, the trial court did not abuse its discretion in denying fees—affirmed on that point.
Bottom line / practical lessons
• Plaintiffs with prior injuries should secure strong, clear expert proof that the crash produced a new/worse condition — juries can and will credit that testimony and appellate courts defer to reasonable inferences.
• Insurers defending UIM exposure should make the record clear about tender/benefit-payment timing; absent evidence of a tender or breach, courts may reject extra (Henson-type) prejudgment interest.
• If attorney’s fees are sought and there’s any jury demand or bifurcation, litigants must preserve and timely present the fees evidence or risk waiver.
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The Girards Law Firm specializes in severe injury and wrongful death cases, especially those that involve birth injuries, brain damage, heart damage, spinal cord injuries, severe burns, commercial plane crashes and commercial trucking crashes nationwide, and especially in Texas, Arkansas and Oklahoma. James E. Girards is a private pilot licensed to fly single- and multi-engine aircraft in both visual and instrument conditions. Contact us at www.girardslaw.com by using the chat feature for more information.