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Aig Aviation (Texas), Inc. v. Holt Helicopters, Inc.
Citations: 248 S.W.3d 169; 51 Tex. Sup. Ct. J. 313; 2008 Tex. LEXIS 47; 2008 WL 109078Docket: 06-0484
Court: Texas Supreme Court; January 11, 2008; Texas; State Supreme Court
AIG Aviation (Texas, Inc.) and National Union Fire Insurance Company petitioned the Supreme Court of Texas regarding a dispute with Holt Helicopters, Inc. The court denied a motion for rehearing, with Justice Willett dissenting. Willett emphasized the principle that insurance contracts should be enforced according to their explicit terms, as established in previous cases involving healthcare, homeowners, and commercial liability insurance. However, he criticized the precedent set in Puckett v. U.S. Fire Insurance Co., where a causal-connection requirement was imposed on aviation insurance contracts. This case allowed coverage to be denied based on public policy, despite clear contractual exclusions, which Willett argued undermines the integrity of contract enforcement. He contended that the approach taken in Puckett conflicts with the court's standard practice of adhering to the written terms of contracts and called for either overruling, distinguishing, or clarifying the reasoning behind the different treatment of aviation insurance contracts. Willett maintained that uniformity in contract interpretation is essential and that aviation contracts should not receive special interpretive standards. He reiterated the importance of enforcing unambiguous contracts as intended by the parties. Justice Duncan's dissent in the court of appeals in R. P Enters. v. LaGuarta, Gavrel, Kirk, Inc. emphasized the distinction between the case at hand and the precedent set in Puckett. He argued that the policy exclusion for minimum pilot experience was fundamental to the agreement, contrasting it with the airworthiness certificate issue in Puckett, which he viewed as an insignificant technicality. The dissent pointed out that the anti-technicality statute, which excuses breaches of insurance policy conditions unless they directly caused property destruction, does not apply to aviation insurance but only to fire and personal property insurance, as specified in Tex. Ins. Code. 862.054. Additionally, it noted that most courts uphold the principle that a causal link between a policy breach and an accident does not need to be established when pilot-related policy requirements are violated.