The Texas Supreme Court held that three sections of the Texas Insurance Code, referred to as the Emergency Care Statutes and requiring a health insurance company to pay non-network physicians for emergency care at the usual and customary rate, do not authorize a private right of action by physicians against insurers for payment of claims that accrued prior to January 2020. (Since January 2020, the Insurance Code requires out-of-network providers and insurers to complete a mandatory arbitration process before a suit for judicial review may be filed.) The Supreme Court also held that the physician-plaintiffs' claims for recovery in quantum meruit and for unfair settlement practices failed as a matter of law.