Hayseeds, Inc. v. State Farm Fire & Cas.

Summary

The court upheld the insureds’ recovery on the fire-insurance policy, consequential damages, and attorney’s fees, concluding that the evidence supported the jury’s rejection of State Farm’s arson defense and that the instruction on that defense was sufficiently accurate. It established that a policyholder who substantially prevails in a property-damage action against the insurer may recover reasonable attorney’s fees, net economic loss caused by delayed payment, and aggravation and inconvenience, without proving bad faith. The court reversed the punitive-damages award because the evidence did not show the required actual malice: knowing that the claim was proper and intentionally denying it.