Questions to Ask a Dallas Car Accident Attorney | GoSuits

• What are the must-ask questions for a Dallas car accident attorney consultation?
• How do Texas car accident laws shape my claim strategy in Dallas?
• What Dallas courts and procedures should my lawyer be familiar with?
• What evidence should I gather right now to protect my Dallas car crash claim?
• What is the statute of limitations in Texas and are there exceptions for car crashes?
• How do contingency fees and case costs work for a Dallas car crash case?
• What should I ask about insurance claim negotiation, UM/UIM, and PIP in Texas?
• How are medical bills, hospital liens, and subrogation handled in Texas?
• What damages can I claim and how are they proven in Texas car accident cases?
• Should I settle or go to trial in Dallas and what is a realistic timeline?
• How should I evaluate a firm’s communication style and technology?
• How do recorded statements and social media affect a Dallas car accident case?
• What if the at-fault driver was uninsured, underinsured, or fled the scene?
• Could my Dallas case be moved to federal court and how would that change things?
• How do Texas comparative fault rules affect settlement value?
• Which DFW roadways and local issues should I discuss with my lawyer?
• What documents should I bring to a free consultation with a Dallas car crash lawyer?
• What bilingual or accessibility questions should I ask a Dallas personal injury lawyer?
• What ethical safeguards and conflicts checks should I confirm under Texas rules?
• How do confidentiality and attorney-client privilege work in Texas?
• What common defenses do insurers raise in Dallas and how are they addressed?
• How are settlements paid in Texas and what happens when my case ends?
• How can GoSuits help with a Dallas car crash case using technology and trial-tested advocacy?
• References and resources used for this guide

What are the must-ask questions for a Dallas car accident attorney consultation?

If you were hurt in a crash anywhere in Dallas-Fort Worth, you deserve straight answers before choosing legal help. A focused set of questions will help you evaluate fit, strategy, and timing. Use this list to guide your consult in Downtown Dallas, Uptown, Oak Lawn, Deep Ellum, Lakewood, East Dallas, West Dallas, and nearby cities like Plano, Irving, Richardson, Garland, Mesquite, Arlington, and Fort Worth.

Start with these high-impact questions:

• Case assessment: What are the strengths, weaknesses, and likely defenses in my case under Texas law?
• Liability and proof: What evidence should we secure now, and who will preserve it?
• Medical bills and liens: How will hospital liens and insurance subrogation be handled at settlement under Texas statutes?
• Insurance strategy: What is the plan for dealing with the other driver’s insurer and my UM/UIM or PIP coverage?
• Comparative fault: How could Texas proportionate responsibility affect my recovery if I am alleged to be partly at fault?
• Timeline: What is the expected timeline for demand, negotiation, filing, and potential trial in Dallas County courts?
• Fees and costs: How does the contingency fee work, what costs are advanced, and how are they reconciled?
• Communication: How often will we talk, who is my point of contact, and are you available in Spanish?
• Trial readiness: How often do you try cases, and what will trial preparation involve if settlement stalls?
• Results and transparency: Can I review representative cases similar to mine and see redacted closing statements?

Ground your questions in Texas law and Dallas procedures. The sections below explain what to listen for as lawyers answer.

How do Texas car accident laws shape my claim strategy in Dallas?

Texas law frames liability, deadlines, and damages for collisions in North Texas. Knowing these rules helps you ask sharper questions.

• Negligence and duty: You generally must show the other driver owed a duty, breached it, and caused your injuries with resulting damages. This is the foundation of most Dallas car crash claims.
• Comparative fault: Texas follows proportionate responsibility. If you are 51 percent or more responsible, you cannot recover damages. If you are 50 percent or less responsible, your damages are reduced by your percentage of fault. Ask how the firm evaluates and counters fault arguments. See Texas Civil Practice and Remedies Code Chapter 33 [1].
• Statute of limitations: Most Texas personal injury claims must be filed within two years of the crash. There are narrow exceptions, including tolling for minors and persons of unsound mind. See Tex. Civ. Prac. & Rem. Code §§ 16.003 and 16.001 [2][3]. Ask how the firm calendars and preserves deadlines.
• UM/UIM and PIP: Texas insurers must offer uninsured and underinsured motorist coverage and personal injury protection. You can reject in writing. These coverages can be critical in hit-and-run or underinsured situations. See Texas Insurance Code Chapter 1952 [4], including §1952.151 on PIP.
• Hospital liens: Texas hospital liens may attach to third-party recoveries for accident-related care provided within statutory limits. Understanding lien scope helps you forecast net recovery. See Texas Property Code Chapter 55 [5].
• Exemplary damages: Punitive damages are capped by statute in most cases, with specific formulas and exceptions. See Tex. Civ. Prac. & Rem. Code §41.008 [6]. Ask how liability facts might support or narrow a claim for exemplary damages.

Use these rules to probe how a lawyer will build liability, preserve claims, and maximize legally available coverage.

What Dallas courts and procedures should my lawyer be familiar with?

Local knowledge can smooth a case. In Dallas, car accident lawsuits typically proceed in county or district courts, depending on the amount in controversy. Pre-suit practice also matters, including negotiation and mediation.

• Where will the case be filed: Ask the attorney which Dallas County court they anticipate filing in and why. Confirm familiarity with local court practices. See the Dallas County District Clerk resources for filings and civil procedures [7].
• Governing rules: Civil suits follow the Texas Rules of Civil Procedure and Texas Rules of Evidence, as updated by the Supreme Court of Texas [8]. Ask how the firm uses discovery tools and evidence rules to compel production and exclude improper defenses.
• ADR and mediation: Many Dallas judges encourage early mediation. Ask how mediation is approached and when it is most effective in the DFW market.
• Remote options: Since 2020, courts have used remote hearings in some settings. Clarify whether depositions or initial hearings may proceed remotely and how that affects cost and speed.

What evidence should I gather right now to protect my Dallas car crash claim?

Evidence can disappear quickly in Dallas traffic. Preserve what you can and coordinate with your lawyer for subpoenas and preservation letters.

• Crash report: Order the official Texas CR-3 crash report through the state portal. The report number may be on the officer’s card. See the Texas Crash Records Information System (CRIS) portal [9].
• Scene evidence: Photos, videos, dashcam clips, skid marks, debris fields, lighting, signage, weather, and lane markings. A prompt site visit can matter, specifically on interchanges like I-35E, I-30, I-635, US-75, and Woodall Rodgers.
• Witnesses: Get names, phone numbers, and emails. Your lawyer can take recorded statements and later sworn depositions.
• Vehicle data: Ask about preservation letters for event data recorders, fleet telematics, and rideshare logs. Timely notice can be critical.
• Medical documentation: Save discharge summaries, imaging, prescriptions, and bills. Keep a symptom and activity diary to track pain and limitations.
• Employment records: Pay stubs, timesheets, W-2s, and supervisor notes help prove lost wages or diminished earning capacity.

What is the statute of limitations in Texas, and are there exceptions for car crashes?

Ask any Dallas car accident attorney to explain deadlines carefully so you do not lose your claim.

• General deadline: Two years from the date of injury for personal injury and wrongful death claims, subject to statutory nuances, under Tex. Civ. Prac. & Rem. Code §16.003 [2].
• Tolling: The limitations period may be tolled for minors and persons of unsound mind under §16.001 [3]. Ask how tolling applies to specific claimants in your family.
• Government defendants: If a governmental unit is involved, additional notice and shorter deadlines may apply under the Texas Tort Claims Act. Clarify immediately if a city, county, or state vehicle or contractor is implicated.
• Contract claims: First-party claims against your own insurer may have different accrual rules and contractual deadlines. The firm should track both statutory and policy-based time limits.

How do contingency fees and case costs work for a Dallas car crash case?

Understanding fees protects you from surprises and helps you compare options fairly.

• Contingency fee basics: In Texas, injury lawyers commonly work on a contingency fee, paid only from a recovery. The fee agreement should be in writing, state the method of determination, and explain litigation and appeal treatment consistent with Texas professional conduct rules. See Texas Disciplinary Rules of Professional Conduct Rule 1.04 on fees [8][10].
• Case costs: Ask what costs the firm advances, such as records, filing fees, service, depositions, experts, and mediation. Confirm when costs are deducted and how the firm handles costs if a case does not recover.
• Net recovery explanation: Request a sample redacted closing statement showing the sequence: gross settlement, attorney’s fee, costs, medical bills or liens, and final client disbursement.
• Transparency: Ask how often cost reports are shared and whether you will pre-approve higher-cost steps like accident reconstruction.

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What should I ask about insurance claim negotiation, UM/UIM, and PIP in Texas?

Insurance coverage is often the practical ceiling for recovery. Clarify the plan for both third-party and first-party claims.

• Third-party liability: How will the firm verify all liability policies and potential corporate or employer policies if the driver was on the job?
• UM/UIM: Insurers must offer UM/UIM; you can reject in writing. These coverages may pay if the at-fault driver has no or insufficient coverage or is unidentified in a hit-and-run. See Texas Insurance Code Chapter 1952, including §1952.101 and related provisions [4]. Ask how the firm proves the other driver’s legal liability and damages for UM/UIM claims, including the impact of Brainard v. Trinity Universal Ins. Co., which addressed when an insurer owes UM/UIM benefits [11].
• PIP and MedPay: PIP can cover medical bills and lost income regardless of fault unless rejected in writing. Ask how PIP coordinates with health insurance and hospital liens. See §1952.151 and related PIP provisions [4].
• Prompt claim handling: For first-party claims, ask about the Texas prompt payment statute and how the firm documents deadlines and interest if applicable. See Texas Insurance Code Chapter 542 [12].
• Statement strategy: Confirm the firm’s policy on recorded statements to insurers and requests for medical authorizations.

How are medical bills, hospital liens, and subrogation handled in Texas?

Medical billing and lien resolution directly affect your net recovery. Ask for a concrete plan tailored to Texas statutes.

• Hospital liens: Texas Property Code Chapter 55 allows hospitals to assert liens on third-party claims for accident-related care subject to statutory conditions and limits [5]. Ask how the firm will verify lien validity, negotiate reductions, and address facility versus physician claims.
• Health insurance subrogation: Health plans may claim reimbursement. The approach can differ for ERISA self-funded plans versus insured plans, and for government payers. Ask how the firm identifies plan type and negotiates under plan language and applicable law.
• Medicare and Medicaid: Medicare asserts a statutory reimbursement right as a secondary payer, and Medicaid has recovery rights as well. Noncompliance can delay payment and create penalties. See the Medicare Secondary Payer statute at 42 U.S.C. §1395y(b) [13]. Ask about conditional payment resolution and final demand timing.
• Provider balances: Discuss strategies for outstanding balances, charity care policies, or payment plans after settlement if needed.

What damages can I claim, and how are they proven in Texas car accident cases?

Texas law allows recovery of economic and non-economic damages when supported by credible evidence.

• Economic damages: Medical bills, future care, lost wages, loss of earning capacity, household services, and property damage. Proof often includes medical records, CPT billing, wage records, and vocational evaluations.
• Non-economic damages: Physical pain, mental anguish, physical impairment, and disfigurement. These are proven through testimony, medical narratives, photographs, and functional impact evidence.
• Exemplary damages: In cases of malice, fraud, or gross negligence, exemplary damages may be available subject to statutory caps. See Tex. Civ. Prac. & Rem. Code §41.008 [6]. Ask how the firm assesses evidentiary thresholds for this category.
• Mitigation of damages: Texas law expects reasonable steps to mitigate. Ask how to manage care, work, and documentation to avoid avoidable defense arguments.

Should I settle or go to trial in Dallas, and what is a realistic timeline?

Most claims resolve before trial, but your leverage depends on credible trial readiness.

• Demand stage: Many Dallas cases start with a pre-suit demand after medical stabilization. Ask how long the firm waits to send a demand and what documentation is included.
• Mediation: Mediation is common in DFW. Ask about timing and mediator selection for cases in Dallas County, Collin County, Tarrant County, and surrounding courts.
• Litigation timeline: Filing triggers schedules under the Texas Rules of Civil Procedure, including discovery, depositions, motions, and trial settings [8]. Ask for a realistic window to trial in the target court and how the firm handles docket changes.
• Trial plan: Ask what exhibits, witnesses, and demonstratives the firm uses for liability and damages. Clarify who will try the case, how voir dire is approached, and whether bilingual juror communication is available if needed.

How should I evaluate a firm’s communication style and technology?

Fit matters. Your attorney’s communication practices affect clarity, speed, and comfort.

• Point of contact: Will you have direct access to your attorney, and how quickly do they return calls or messages?
• Updates: How often will you receive status reports, and in what format?
• Document handling: Does the firm use secure portals, e-signatures, and centralized evidence management?
• Spanish support: If you prefer Spanish, ask whether communication, documents, and meetings can be handled in Spanish by a bilingual attorney or staff.
• Client education: Will you get plain-language explanations of Texas legal rules that affect your decisions?

How do recorded statements and social media affect a Dallas car accident case?

Insurers routinely ask for recorded statements and broad medical authorizations. Ask the lawyer for a clear protocol.

• Recorded statements: These can be used to minimize your claim. Ask whether the firm will be present for any statement and when it is appropriate to decline.
• Social media: Defense teams search public posts. Ask what to avoid posting, how to adjust privacy, and whether to preserve content to avoid spoliation claims.
• Medical authorizations: Discuss limiting authorizations to relevant time periods and providers rather than open-ended access.

What if the at-fault driver was uninsured, underinsured, or fled the scene?

UM/UIM and PIP may be critical in these scenarios, particularly in hit-and-run crashes in Dallas.

• Hit-and-run: Quickly report the crash to police and your insurer. Timely reporting can matter for UM coverage. Request the CR-3 report through the CRIS portal [9].
• UM/UIM claim proof: You still must prove the other driver’s fault and your damages. Ask how the firm uses scene witnesses, surveillance, forensic vehicle inspections, and medical proof to build the case under Texas Insurance Code Chapter 1952 and applicable case law [4][11].
• PIP coordination: Confirm how PIP will be applied to immediate medical bills and whether any PIP reimbursement is sought by your health plan.

Could my Dallas case be moved to federal court and how would that change things?

Most Dallas car accident lawsuits remain in Texas state courts. Some cases can be removed to federal court if there is diversity of citizenship and the amount in controversy requirement is met under 28 U.S.C. §1332. If removal is a risk, ask:

• Pleading strategy: Does the complaint strategy consider removal risks and joinder of proper local parties?
• Federal procedures: If removed, how will federal deadlines, disclosures, and motion practice differ from Texas state practice?
• Venue implications: Ask about jury pools and trial timelines in the Northern District of Texas compared to Dallas County courts.

How do Texas comparative fault rules affect settlement value?

Texas proportionate responsibility can lower or bar recovery depending on fault allocation. Under Chapter 33, a claimant found 51 percent responsible recovers nothing, while allocations of 50 percent or less reduce damages proportionally [1].

• Ask for a fault grid: Request a scenario analysis showing how different fault splits impact a potential settlement range.
• Evidence plan: What photographs, witness testimony, vehicle data, and roadway engineering evidence will be used to minimize your percentage of fault?
• Defense themes: How will the firm counter common Dallas defense themes, such as sudden emergency, failure to keep a proper lookout, or speed adjustments on I-635 or US-75?

Which DFW roadways and local issues should I discuss with my lawyer?

Dallas traffic patterns can factor into liability and damages. In your consultation, discuss the specific location and conditions.

• High-volume corridors: I-35E, I-30, I-45, I-20, I-635 LBJ, US-75 Central Expressway, President George Bush Turnpike, Dallas North Tollway, Woodall Rodgers Freeway, and major arterials in Uptown, Oak Lawn, and Deep Ellum.
• Construction zones: Ask about signage, lane shifts, and speed control in active work zones.
• Lighting and visibility: Nighttime collisions raise distinct evidence questions. Document illumination, reflectivity, and obstructions.
• Weather and drainage: Stormwater, pooling, and visibility can shape both liability and comparative fault arguments.

What documents should I bring to a free consultation with a Dallas car crash lawyer?

Bringing organized information speeds up your case assessment.

• Identification: Driver’s license, insurance cards, vehicle registration.
• Crash details: Police card or report number, photos, videos, tow receipts, repair estimates, and correspondence from insurers.
• Medical records: ER discharge paperwork, imaging, specialist notes, prescriptions, and bills. Include your health insurance card and explanation of benefits if available.
• Employment records: Recent pay stubs, W-2s or 1099s, time-off records, and employer correspondence.
• Witness information: Names, phone numbers, emails, and any statements or texts.
• Coverage documents: Your auto policy declarations page and any umbrella or excess policies.

What bilingual or accessibility questions should I ask a Dallas personal injury lawyer?

Clear communication is essential. If Spanish is your preferred language or you need accessibility accommodations, ask:

• Bilingual availability: Can meetings, calls, and documents be handled fully in Spanish?
• Interpreter policy: Who pays for interpreter services if needed for depositions or mediations?
• Accessible formats: Can you receive documents in large print, audio, or accessible digital forms?
• Technology access: Are text, WhatsApp, secure chat, or video meetings available for updates?

What ethical safeguards and conflicts checks should I confirm under Texas rules?

Texas legal ethics rules help protect clients. Confirm the firm’s system for screening and disclosure.

• Written fee agreement: Texas professional conduct rules require clarity about the basis or rate of fees. Ask to review the full engagement agreement. See Rule 1.04 and related guidance [8][10].
• Conflicts check: Ask how the firm screens for conflicts with other parties, insurers, or medical providers and how they will notify you of any potential issues.
• Client decision rights: You control settlement decisions. Ask how the firm documents your informed consent for settlement offers.
• Trust accounting: Settlement funds should be held in a trust account with a transparent ledger. Ask about the process for distributing funds and resolving competing claims.

How do confidentiality and attorney-client privilege work in Texas?

Confidentiality and privilege protect your communications and strategy.

• Privilege basics: Communications made for obtaining legal services are generally privileged, with limited exceptions. See the Texas Rules of Evidence for privilege rules [8].
• Scope of confidentiality: Lawyers must maintain client confidences under professional conduct rules, subject to defined exceptions. Ask how your information is stored and who has access.
• Third-party presence: Be careful with third parties in meetings, calls, or group texts, as doing so can affect privilege.

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What common defenses do insurers raise in Dallas and how are they addressed?

Preparing for defenses improves settlement posture and trial readiness.

• Comparative negligence: Allegations you were speeding, distracted, or failed to keep a proper lookout. Ask how the firm uses physical evidence and engineering principles to rebut these claims under Chapter 33 [1].
• Causation disputes: Arguments that injuries were preexisting or not caused by the crash. Ask about medical expert strategy and differential diagnosis.
• Sudden emergency: Claims that a sudden, unexpected event excused the defendant’s conduct. Ask how to test factual support and alternative safer choices.
• Minor impact arguments: Defenses based on repair bills or photos rather than biomechanical analysis. Ask how your lawyer separates visible damage from occupant kinematics and medical findings.

How are settlements paid in Texas and what happens when my case ends?

Closing a case involves careful accounting and documentation.

• Release: You will sign a release of claims. Ask the firm to explain scope, parties released, and confidentiality terms.
• Trust account deposit: Settlement funds are deposited into a client trust account. The firm reconciles fees, costs, and liens before disbursing your net recovery.
• Lien resolution: Confirm how the firm documents hospital lien releases, health plan waivers or reductions, and Medicare or Medicaid final demands under applicable law [5][13].
• Dismissal: The lawsuit is dismissed with prejudice if filed. Ask for copies of all closing documents and a final ledger.

Why do national and Texas crash statistics matter when choosing a Dallas lawyer?

Reliable safety data puts risk and insurer posture in context. The National Highway Traffic Safety Administration reported 42,514 traffic fatalities nationwide in 2022, a slight decrease from 2021 but still historically high [14]. In Texas, state crash data are collected and published by the Texas Department of Transportation. While every case is unique, these statistics remind us that claim evaluation and settlement tactics are shaped by broader risk trends that insurers track closely. A thoughtful attorney should be conversant in these trends while remaining focused on the specific facts of your crash.

How can GoSuits help with a Dallas car crash case using technology and trial-tested advocacy?

If your matter involves a car accident in Dallas-Fort Worth, a free consultation with a personal injury attorney can clarify timelines, coverage options, and strategies for dealing with insurers and medical billing. GoSuits represents clients in Dallas, TX and across North Texas, including Downtown Dallas, Uptown, Oak Lawn, Deep Ellum, Lakewood, East and West Dallas, and nearby communities such as Plano, Irving, Richardson, Garland, Mesquite, Arlington, and Fort Worth.

• Technology-driven workflow: GoSuits uses an exclusive proprietary software platform to accelerate evidence collection, insurer communications, and settlement modeling. This technology is designed to shorten response times and present claim packages in a structured, data-rich format that decision-makers can evaluate quickly.
• Attorney access: Although we leverage technology to expedite the case, every client is represented by a designated attorney. We do not rely on case managers to handle attorney-level work. Clients have unfettered access to their lawyer for strategy discussions, updates, and preparation.
• Proven results: Our team has secured favorable outcomes for injured clients through settlements and verdicts. You can review representative prior cases at GoSuits prior cases. Past results do not predict future outcomes, but they show the types of disputes and resolutions we have handled.
• Trial experience: We prepare every case as if it may be tried in a Dallas courtroom. This approach strengthens negotiation and provides a clear path if settlement stalls.
• 30 years of combined experience: Our attorneys bring three decades of combined courtroom and negotiation experience to personal injury matters, including Dallas car crashes involving liability disputes, UM/UIM claims, PIP coordination, hospital liens, and contested damages.
• Comprehensive injury practice: GoSuits handles a wide range of personal injury matters arising from motor vehicle collisions, pedestrian and bicycle incidents, wrongful death, and premises injuries, always focused on civil claims.
• Bilingual support: Spanish-language communication is available so that clients can fully participate in their case in the language they are most comfortable using.

A short, no-cost consultation can help you understand your options, the Texas laws that apply, and how a technology-enabled, trial-ready approach may serve your goals.

Which Dallas car accident attorney questions are most important to ask first?

For quick reference during your first call or meeting, prioritize:

• Liability and evidence plan: What immediate steps will you take in Dallas to secure videos, data, and witnesses?
• Coverage map: What are the suspected policy limits and how will you discover additional coverage?
• Medical billing strategy: How will you handle hospital liens and health plan reimbursement to protect my net?
• Texas deadlines: How are limitations and notice requirements managed for all claims?
• Communication: Who is my attorney contact, and do you offer Spanish-language support if needed?
• Fees and costs: How are fees and costs calculated and reported at closing?
• Trial posture: If the insurer undervalues my claim, what is the plan to file and prepare for trial in Dallas County?

Why is hiring counsel important instead of handling a Dallas car crash claim alone?

Texas civil procedure, comparative fault rules, and insurance practices are technical and deadline-driven. Adjusters and defense counsel are trained to minimize claims. An attorney can navigate Texas statutes, rules of evidence, and lien laws, develop admissible proof, and present a litigation-ready demand. This often changes how insurers evaluate a claim. Even if you choose to resolve the case before suit, your preparation and leverage can be materially different with legal help.

References and resources used for this guide

• [1] Texas Civil Practice and Remedies Code Chapter 33, Proportionate Responsibility: https://statutes.capitol.texas.gov/Docs/CP/htm/CP.33.htm
• [2] Tex. Civ. Prac. & Rem. Code §16.003, Limitations for Personal Injury and Wrongful Death: https://statutes.capitol.texas.gov/Docs/CP/htm/CP.16.htm#16.003
• [3] Tex. Civ. Prac. & Rem. Code §16.001, Tolling for Legal Disability: https://statutes.capitol.texas.gov/Docs/CP/htm/CP.16.htm#16.001
• [4] Texas Insurance Code Chapter 1952, Motor Vehicle Insurance: https://statutes.capitol.texas.gov/Docs/IN/htm/IN.1952.htm
• [5] Texas Property Code Chapter 55, Hospital Liens: https://statutes.capitol.texas.gov/Docs/PR/htm/PR.55.htm
• [6] Tex. Civ. Prac. & Rem. Code §41.008, Cap on Exemplary Damages: https://statutes.capitol.texas.gov/Docs/CP/htm/CP.41.htm#41.008
• [7] Dallas County District Clerk, Civil Information: https://www.dallascounty.org/departments/district-clerk/
• [8] Supreme Court of Texas, Rules and Standards including Texas Rules of Civil Procedure and Evidence: https://www.txcourts.gov/rules-forms/rules-standards/
• [9] Texas Crash Records Information System (CRIS) Public Portal for CR-3 crash reports: https://cris.dot.state.tx.us/public/Query/app/home
• [10] Texas Disciplinary Rules of Professional Conduct, Fee Rule Reference via Texas State Law Library guide to court rules: https://guides.sll.texas.gov/texas-law/court-rules
• [11] Brainard v. Trinity Universal Ins. Co., 216 S.W.3d 809 (Tex. 2006) discussion of UM/UIM payments: https://www.courtlistener.com/opinion/1458217/brainard-v-trinity-universal-ins-co/
• [12] Texas Insurance Code Chapter 542, Processing and Payment of Claims: https://statutes.capitol.texas.gov/Docs/IN/htm/IN.542.htm
• [13] Medicare Secondary Payer statute, 42 U.S.C. §1395y(b): https://www.law.cornell.edu/uscode/text/42/1395y
• [14] National Highway Traffic Safety Administration, 2022 Traffic Crash Data Press Release: https://www.nhtsa.gov/press-releases/2022-traffic-crash-data-fatalities