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Perspectives

| 1 minute read

Back to Basics: Texas Supreme Court Reaffirms Ordinary‑Meaning Approach in Policy Interpretation

The Texas Supreme Court’s recent decision in Privilege Underwriters Reciprocal Exchange v. Mankoff (Feb. 13, 2026) offers a clear example of the Court’s reliance on ordinary‑meaning principles when interpreting undefined terms in insurance policies. The issue before the Court was whether a policy’s “Windstorm or Hail” deductible applied to damage caused by a tornado — an inquiry that turned on the meaning of “windstorm,” a term the policy did not define. 

The Court consulted multiple dictionary definitions, each describing a windstorm as a storm characterized by strong or violent winds, typically with little or no precipitation. Based on those sources, the Court concluded that a tornado falls within that ordinary meaning.

The opinion also reviewed other authorities cited by the parties — including statutory references, historic case law, media usage, and meteorological materials — but ultimately found that none displaced the ordinary‑meaning analysis. The Court emphasized that while tornadoes may be classified separately for certain purposes, those classifications do not alter the plain meaning of the term “windstorm” in this context. 

By grounding its reasoning in widely accepted dictionary definitions and long‑standing interpretive principles, the Court reinforced an important baseline: When policies leave terms undefined, courts will default to everyday usage rather than specialized distinctions. For insurers, policyholders, and practitioners, the decision underscores the significance of precise drafting, especially when parties intend for technical or industry‑specific meanings to control.

The ruling ultimately reinstated the trial court’s judgment and held that the deductible applied. But more broadly, it serves as a straightforward example of the Court’s commitment to beginning — and often ending — with the basics.

“[W]e typically look first to . . . dictionary definitions and then consider the term’s usage in other statutes, court decisions, and similar authorities.”