Texas Department of Insurance v. American Home Assurance Co.

JAN P. PATTERSON, Justice.

American Home Assurance Company and the Insurance Company of the State of Pennsylvania (collectively “appellees”) sued appellants (collectively “the State”) for a partial refund of taxes and interest paid to the State under protest. The parties filed cross-motions for summary judgment. The district court denied the State’s motion and granted summary judgment in favor of appellees. We will affirm the judgment of the district court.

THE CONTROVERSY

This is a case involving workers’ compensation insurance taxes assessed annually under the Texas Workers’ Compensation Act 2…