The Texas Supreme Court officially closed the door on the ability of workers’ compensation claimants to seek supplemental relief under the Texas Insurance Code. In Texas Mutual Ins. Co. v. Ruttiger, — S.W.3d —, No. 08-751 (Tex. Aug. 26, 2011), the Court held that the Texas Workers’ Compensation Act (“Act”) preempts claims against workers’ compensation insurers for unfair or “bad faith” settlement practices under the Texas Insurance Code.