Reasonable Payment Prior to Appraisal Not a Defense to Prompt Pay Penalties:
Today Texas Supreme Court extended its holding in Barbara Tech. Corp. v. State Farm Lloyds that payment of an appraisal award does not extinguish penalty interest or attorney’s fees under the Prompt Payment of Claims Act. 589 S.W.3d 806 (Tex. 2019). The Court categorically rejected the “reasonable undisputed payment” defense as inconsistent with Barbara Tech. See Hinojos v. State Farm…