Once upon a time, the relationship between insurer and insured was one of contract and was governed by the terms and conditions of the policy.
New Approach to Policy Interpretation
Three decisions ' <i>Fortis Benefits v. Cantu,</i>; <i>Mid-Continent Insurance Co. v. Liberty Mutual Insurance Co.,</i>; and <i>Excess Underwriters at Lloyd's v. Frank's Crew & Rental Tools, Inc.</i> ' appear to reflect the Texas Supreme Court's view that courts applying Texas law should not read more into policies than what is expressly included. And, if there is an agreement apart from the insurance contract, the Texas Supreme Court will look for it to be in writing.
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