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Keywords

lawsuitliabilitytrial
plaintiffdefendanttrialappellantappellee

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Aetna Life Ins. Co. v. Bocanegra, 572 S.W.2d 355

Facts

Janie P. Bocanegra filed a lawsuit against Aetna Life Insurance Company to recover medical expenses under a group health insurance policy while employed at the Clegg Company. Prior to this suit, she had filed a claim with the Texas Industrial Accident Board for the same injury, believing it to be work-related. Although the workmen's compensation insurer disputed liability, they eventually settled for lost wages and future earning capacity, without covering medical expenses. The court found that Bocanegra's claims were inconsistent, as she had previously asserted that her injury was work-related.

Issue

Whether Janie P. Bocanegra is estopped from claiming benefits under the group health policy after receiving workmen's compensation for the same injury.

Defendant's contention, as stated in its brief, is as follows: Appellant says that by virtue of the Appellee's filing such claim with the Industrial Accident Board of the State of Texas and securing workmen's compensation benefits from the Fireman's Fund, which was the workmen's compensation carrier for The Clegg Company, she is estopped to make a claim against Appellant for medical expenses under the group policy which would only cover expenses if the claim were to arise out of a non-occupational injury and/or disease.

Rule

If one having a right to pursue one of several inconsistent remedies makes his election, institutes suit, and prosecutes it to final judgment, or receives anything of value under the claim thus asserted, such election constitutes an estoppel thereafter to pursue another and inconsistent remedy.

If one having a right to pursue one of several inconsistent remedies makes his election, institutes suit, and prosecutes it to final judgment, Or receives anything of value under the claim thus asserted, or if the other party has been affected adversely, such election constitutes an estoppel thereafter to pursue another and inconsistent remedy.

Analysis

The court applied the rule of estoppel by determining that Bocanegra's previous claim for workmen's compensation, where she asserted her injury was work-related, was inconsistent with her current claim under the health policy, which she argued was for a non-occupational injury. Since she had already received benefits from the workmen's compensation claim, the court concluded that she could not pursue a second, inconsistent claim for medical expenses under the health policy.

The plaintiff should not be permitted to assert formally the existence of one state of facts in a claim against one party and accept benefits in satisfaction of that claim, and then maintain an action against another party on the ground that the facts first asserted didn't exist.

Conclusion

The court reversed the trial court's judgment and rendered judgment that Bocanegra take nothing from Aetna Life Insurance Company.

The judgment of the trial court is reversed and judgment here rendered that plaintiff take nothing.

Who won?

Aetna Life Insurance Company prevailed in the case because the court found that Bocanegra was estopped from claiming benefits under the health policy after having received workmen's compensation for the same injury.

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