SECTION VIII: Analysis of Institutional Failure: American National Insurance (ANI)

ANI's actions constitute a textbook case of statutory bad faith and a breach of contract. ANI seized upon the LPD's corrupt and discriminatory "civil matter" narrative to avoid its contractual obligations.

       
  • Breach of Contract (Failure to Investigate): ANI had a contractual duty under its policy (A74.pdf) to conduct a fair and independent investigation. It failed to do so.        
                 
    • Day 1 Failure: The investigation was flawed from its inception on July 19, 2024, when adjuster David Skinner refused to record the claimant's full report of subsequent damages (A102.pdf).
      •            
    • Adoption of Pretext: ANI adopted the LPD's false "no police report" pretext (A94.pdf) rather than investigating why the report was blocked.
      •        
       
    •    
  • Motive (Strategic Market Exit): ANI's bad faith was not a procedural error but a calculated business strategy. In February 2024, ANI publicly announced its decision to exit the homeowners insurance market in Oklahoma. ANI's denial of this high-value claim, which occurred just months later, is evidence of a strategy to "clear the books" and minimize losses prior to its departure.
    •    
  • Material Misrepresentation to State Regulators: ANI's SIU (Heather Broyles) lied to the Oklahoma Insurance Department in writing (A100.pdf):        
                 
    1. False Date: She falsely claimed Skinner spoke to the claimant on July 18 ("the same day") when the transcript proves it was July 19 (A92.pdf).
      2.            
    2. False Narrative: She falsely claimed the claimant knew the suspect from the "county jail," a defamatory statement contradicted by LPD's own file, which noted the professional Peer Review Board relationship (A60.pdf, A61.pdf).
      3.            
    3. False "Late Reporting" Claim: She falsely accused the claimant of "late reporting," which is disproven by LPD's own logs showing the claimant reporting the burglary live, in progress on June 1st (A10.pdf).
      4.        
       
    •    
  • Adoption of Contradictory Witness Testimony: ANI's SIU built its denial narrative by treating the suspect (Theleka Williams) as a credible "expert witness" regarding the "civil matter" pretext. However, the evidence proves that during this same period (Dec 2024), this "expert witness" was authoring fraudulent letters (e.g., A80.pdf, A97.pdf, A98.pdf, A99.pdf) which corroborated the claimant's core allegations (e.g., "hired crew," "cops did NOTHING!"). ANI cannot legally or logically "pick and choose" which parts of its star witness's testimony to believe. This proves ANI knowingly used a false pretext.
    •    
  • Adoption of Fraudulent Evidence: ANI used a fraudulent "confession" letter (A90.jpg) as a pretext. This letter was planted by an associate of the suspect, who was filmed delivering it in a Red Sedan (A93.jpg)—a vehicle LPD later identified at the scene of another break-in and linked to the suspect (A150.pdf).
    •    
  • Federal-Level Fair Housing Act Violation: ANI adopted LPD's false "mental health" narrative as its own. The claimant notified Det. Adamson that ANI was using the officer's "schizophrenic" comment in its report to the State Insurance Board (A58.pdf). By using a perceived mental disability as a pretext to deny a housing-related claim, ANI engaged in active discrimination.
    •    
  • Final Consequence (Guaranteed Foreclosure): By denying the claim and simultaneously exiting the Oklahoma market, ANI left the claimant with a damaged, uninhabitable, and uninsurable property. This made it impossible to sell, repair, or refinance, thus ensuring the foreclosure would be completed.
  • Actions of Retained Counsel & Vicarious Liability: ANI's retained counsel, Bill Cathcart, engaged in actions that constitute deliberate obstruction. These actions create direct vicarious liability for ANI. The actions include:        
                 
    1. Scheduling the EUO at the office of the suspect's known law firm (Zelbst, Holmes & Butler) (A116.pdf), forcing the claimant to formally object due to the conflict (A77.pdf).
      2.            
    2. Failing to schedule a court reporter for the rescheduled EUO in February 2025, forcing its cancellation after the policyholder had already traveled two hours in hazardous conditions.
      3.            
    3. Focusing interrogation during the final EUO attempt on harassing, irrelevant matters (e.g., 20-year-old work history, the claimant's adult daughter and her mother's address) unrelated to the property, the suspects, or the claim.
      4.            
    4. Formally and illegally withholding the claimant's own case file, stating in writing, "you are not entitled information developed during American National's investigation" (A111.pdf).
      5.        
       
    •    
  • Failure to Provide Contractual Benefits: Despite being formally notified that the home was uninhabitable (no AC, A32.pdf) and contained suspected surveillance devices in a minor's bathroom (A96.mp4, A70.pdf), ANI failed to offer Additional Living Expenses (ALE), a benefit provided under "Coverage D-Loss of Use" in the claimant's policy (A74.pdf).