Evanston Insurance Co. v. Legacy of Life, Inc., 370 S.W.3d 377 (Tex. Sup. Ct. 2012)

(certified question from federal court on whether duty to defend suit against organ donation charity existed; daughter of deceased woman sued organ donation charity in federal court for emotional distress caused by charity’s misrepresentation that it would not profit from donation of mother’s organs; court held emotional distress claim absent physical injury did not fall within policy coverage for personal injury; court also held that neither next of kin nor estate have property rights in tissues of deceased person under Anatomical Gift Act; court held without property rights, no loss of use of tangible property as defined by policy existed; no coverage under policy for claims made by plaintiff, so insurance company has no duty to defend suit).