I read your evaluation of Richardson. A super read, but I just wondered what you make of early holdings like United Services Auto. ***’n v. Zeller, 135 S.W.2d 161 (Tex.Civ.App.San.Antonio 1939). Did older cases like Zeller already vitiate the otherwise harsh impact of the no-direct-action rule by reading the right of direct action into an otherwise silent policy — and do they continue to do so post-Richardson?
I read your evaluation of Richardson. A super read, but I just wondered what you make of early holdings like United Services Auto. ***’n v. Zeller, 135 S.W.2d 161 (Tex.Civ.App.San.Antonio 1939). Did older cases like Zeller already vitiate the otherwise harsh impact of the no-direct-action rule by reading the right of direct action into an otherwise silent policy — and do they continue to do so post-Richardson?