Crown Life Insurance Co. v. Estate of Gonzalez

We consider whether a party who otherwise timely files a record on appeal should be granted pre-submission leave to supplement the record absent any finding of unreasonable delay. We conclude that Tex. R.App.P. 55(b) should be liberally construed so that in such cases, leave should be granted.

This cause arises from a claim of bad faith filed against Crown Life Insurance Company (Crown) by the Estate of Eduardo J. Gonzalez (the Estate). Following the trial court’s grant of summary judgment in favor of the Estate, Crown appealed. After the case was set for submission in the court of appeals,…