Brandon Forvendel v. State Farm Mutual Automobile Insurance Company

Summary

The court held that State Farm did not waive its statutory and policy defenses to the plaintiff's 2013 uninsured-motorist claim by mistakenly paying benefits on his separate 2007 claim. The waiver doctrine applied in a single proceeding does not extend across separate claims merely because the insurer previously made an erroneous payment. The court reversed the court of appeal and rendered judgment dismissing the plaintiff's claims with prejudice.