Justia Civil Procedure Opinion Summaries

Articles Posted in Insurance Law
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The case involves Sherry and David Lewis, who sued their auto insurer, GEICO, for allegedly breaching their insurance contract when their car was totaled. The Lewises claimed that GEICO undercompensated them by applying a "condition adjustment" that artificially reduced its valuation of their car and by failing to reimburse them for taxes and fees necessary to replace the car. They sought to certify a class of similarly underpaid insureds for each instance of underpayment.The District Court certified both classes under Federal Rule of Civil Procedure 23. GEICO appealed the decision, challenging the certification of the classes.The United States Court of Appeals for the Third Circuit affirmed the order certifying the class for the taxes-and-fees claim. However, the court found that the Lewises lacked standing to bring the condition-adjustment claim as they failed to show that GEICO caused them concrete harm when it applied the condition adjustment. Therefore, the court vacated the District Court’s order in part and remanded with instructions to dismiss the condition-adjustment claim.Regarding the taxes-and-fees claim, the court found that the Lewises met the requirements for standing as they alleged financial harm stemming from GEICO's pre-2020 practice of declining to pay taxes and fees to lessee insureds. The court also found that the class was ascertainable, meeting the requirements for class certification. View "Lewis v. GEICO" on Justia Law

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The case involves the Government Employees Insurance Company (GEICO) and its affiliates, who sued several medical practices in separate actions in the District of New Jersey. GEICO alleged that the practices defrauded them of more than $10 million by abusing the personal injury protection (PIP) benefits offered by its auto policies. The practices filed exaggerated claims for medical services, billed medically unnecessary care, and engaged in illegal kickback schemes. GEICO's suits against the practices each included a claim under the New Jersey’s Insurance Fraud Prevention Act (IFPA).The practices sought arbitration of GEICO’s IFPA claim, arguing that a valid arbitration agreement covered the claim and that a different New Jersey insurance law allowed them to compel arbitration. However, each District Court disagreed, ruling instead that IFPA claims cannot be arbitrated. The practices appealed to the United States Court of Appeals for the Third Circuit.The Third Circuit Court of Appeals reversed the lower courts' decisions and compelled arbitration. The court found that the IFPA does not implicitly prohibit arbitration. The court also found that the IFPA claims before them should be compelled to arbitration under a different New Jersey law. Furthermore, the court concluded that GEICO’s IFPA claims must be compelled to arbitration under the Federal Arbitration Act (FAA). The court held that the arbitration agreement in the Plan covers the IFPA claims and therefore, must compel arbitration. The court also addressed practice-specific issues in the Mount Prospect and Precision Spine appeals. The court concluded that the District Court should not have granted GEICO leave to amend its complaint in the Mount Prospect case. In the Precision Spine case, the court held that the District Court abused its discretion by denying Precision Spine’s motion sua sponte because it was addressed to the unamended complaint. View "GEICO v. Mount Prospect Chiropractic Center PA" on Justia Law

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The case involves Dennis Neate, a former employee of the James B. Oswald Company (Oswald), an insurance firm. Neate left Oswald to work for Hylant Group, Inc., another insurance firm, and some of his clients followed him. Oswald accused Neate of violating his non-solicitation agreement and sued in federal district court. The court issued a preliminary injunction ordering Neate and others to comply with Oswald’s non-solicitation agreement. Neate appealed.Previously, the district court granted a preliminary injunction after an evidentiary hearing. The injunction prohibited Neate and others from violating their agreements with Oswald, retaining or using Oswald's confidential information, and soliciting or accepting business from Oswald's clients. The injunction also required all defendants to return all of Oswald's property.The United States Court of Appeals for the Sixth Circuit vacated and remanded the case. The court found that the district court failed to properly apply Ohio law in determining the reasonableness of the non-solicitation agreement. The court also found that the injunction did not meet the specificity requirements of Federal Rule of Civil Procedure 65(d)(1), as it incorporated the non-solicitation agreement by reference. However, the court agreed with the district court that Oswald had shown a likelihood of success on its trade-secrets claims. View "James B. Oswald Co. v. Neate" on Justia Law

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The case revolves around a dispute over insurance coverage following a fatal jet ski accident. The owner of A.C. Watercraft Rental, Sayed Mohammed, had sought liability insurance for all his business-owned watercraft through Farm Bureau Property and Casualty Insurance Company, which connected him with Great Divide Insurance Company. However, a Yamaha watercraft involved in a fatal accident was not listed in the policy schedule. Following the accident, Mohammed filed a claim with Great Divide for defense and indemnification, which was denied due to the jet ski not being listed in the policy. Subsequently, the deceased's father, Garbis Satamian, sued A.C. Watercraft, which had to bear its own defense costs.The Superior Court in Maricopa County dismissed Satamian's claims against Great Divide, Farm Bureau, and Risk Placement Services (RPS) on the grounds of statute of limitations. The court found that A.C. Watercraft learned of the negligent procurement of insurance when Great Divide denied coverage in January 2016, and that it “sustained injury in May 2017, when [A.C. Watercraft] incurred attorneys’ fees and costs defending itself.” The court ruled that both the negligent procurement of insurance claim and the promissory estoppel claim were time-barred because each accrued no later than May 2017.Satamian appealed the dismissal, arguing that the discovery rule should have tolled the statute of limitations and that the claims could not have accrued until his underlying action against A.C. Watercraft was final and non-appealable. The Court of Appeals rejected Satamian’s arguments and affirmed the lower court's decision.The Supreme Court of the State of Arizona affirmed the lower courts' decisions, holding that the negligent procurement of insurance and promissory estoppel claims accrued when an insured incurs its own litigation costs for defense against a claim due to an insurer’s negligent failure to obtain insurance coverage. The court found that A.C. Watercraft knew or should have known both the “who” and the “what” of the negligent procurement cause of action by May 2017, and expired by May 2019. The promissory estoppel claim began to accrue by May 2017, and expired by May 2020. Because Satamian filed this lawsuit in June 2021, both claims were time-barred. View "Satamian v. Great Divide Insurance Co." on Justia Law

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The case revolves around a car accident that occurred on February 6, 2016, involving Melissa A. Keller and her daughter, Caroline Keller, who were insured by State Farm Mutual Automobile Insurance Company. The Kellers were hit by Xavier Blanchard, who ran a red light. Xavier's vehicle was owned by his father, Harvey Blanchard, and was also insured by State Farm. The Kellers filed a complaint against the Blanchards on January 8, 2018, alleging negligence and wantonness. However, the complaint did not state any claim against State Farm. On January 26, 2023, the Kellers settled their claims with the Blanchards and subsequently filed an "Amended Complaint for Underinsured Motorist Coverage" against State Farm on January 27, 2023.State Farm moved to dismiss the new complaint, arguing that it was filed outside the six-year statute-of-limitations period applicable to contract-based claims. The insurer contended that the claim did not relate back to the original complaint as Keller knew or should have known that State Farm was her insurer. Keller, on the other hand, argued that her claim for underinsured-motorist coverage did not accrue until the date she settled with the Blanchards. The trial court denied State Farm's motion to dismiss on June 12, 2023, without making specific findings of fact or law.The Supreme Court of Alabama granted State Farm's petition for a writ of mandamus, directing the trial court to dismiss Keller's underinsured-motorist claim against it. The court held that the accrual date for a direct uninsured/underinsured-motorist claim against an insurer is the date of the accident. Since Keller did not assert her direct claim for underinsured-motorist benefits against State Farm until more than six years after the date of the accident, that claim was time-barred. View "Ex parte State Farm Mutual Automobile Insurance Company" on Justia Law

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In this case, the plaintiffs, Carl and Mary Ellen Schnell, filed an insurance claim with their home insurer, State Farm Lloyds, after a hailstorm damaged their home's roof. State Farm accepted coverage for some claims but denied others, including the claim that the City of Fort Worth required the Schnells to replace their entire roof, rather than just the damaged tiles. The Schnells sued, and the district court ruled in favor of State Farm. The Schnells appealed this decision.The United States Court of Appeals for the Fifth Circuit found that there were genuine issues of material fact that prevented the case from being resolved through summary judgment. The court found conflicting evidence regarding whether a building code administrator had flatly denied the Schnells' request for spot repairs or had conditioned his decision on the Schnells confirming that the old and new tiles on their roof did not interlock. The court also found a genuine dispute of fact about whether the Schnells' roof tiles were damaged by a covered risk like wind or hail, which would have triggered their insurance coverage.Thus, the court vacated the district court's summary judgment in favor of State Farm on the Schnells' breach of contract and Texas Prompt Payment of Claims Act claims. The court affirmed the remainder of the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Schnell v. State Farm Lloyds" on Justia Law

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This case involved Safeco Insurance Company (Safeco) appealing against the trial court's dismissal of its third-party spoliation and negligence claims against the Michaelis Corporation. The dispute originated from a fire in a home insured by Safeco, which resulted in over $500,000 worth of damage. Safeco hired Michaelis to restore the property, and during this process, the kitchen, identified as the origin of the fire, was demolished and the dehydrator believed to have caused the fire was discarded. Safeco subsequently sued Michaelis for negligence and spoliation of evidence, arguing this impeded its ability to bring a successful claim against the dehydrator manufacturer.The trial court dismissed both claims, sparking Safeco's appeal. The Indiana Supreme Court held that under the given facts, Indiana common law did not recognize the tort of third-party spoliation and therefore upheld the trial court’s ruling. The court established that a special relationship did not exist between Safeco and Michaelis that would impose a duty on Michaelis to preserve the evidence. Furthermore, the court ruled it was not reasonably foreseeable that Safeco would be harmed by the loss of the dehydrator. Public policy considerations also weighed against recognizing third-party spoliation absent a special relationship.In addition, the court ruled that Safeco's negligence claim was essentially a third-party spoliation claim and failed for the same reasons. The court also dismissed Safeco's argument that Michaelis assumed a duty of care to preserve the evidence, as this was not alleged in the amended complaint and was raised for the first time on appeal. View "Safeco Insurance Company of Indiana v. Blue Sky Innovation Group, Inc" on Justia Law

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This case involves a dispute between Zhen Feng Lin, a food delivery driver who was severely injured in a car accident, and his employer's insurance company, Hartford Accident and Indemnity Company. After the accident, Lin received a settlement from the at-fault driver's insurance company, and workers' compensation benefits from his employer's insurance carrier, Hartford Fire Insurance Company. Lin later sought additional recovery under his employer's underinsured motorist policy with Hartford Accident.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision that Lin and Hartford Accident had not entered into a "settlement agreement" as defined by the insurance policy. As a result, the court ruled that the policy limits should be reduced by the amount Lin received in workers' compensation benefits. The court also agreed with the district court that Lin should be credited for the amount he paid to settle the workers' compensation lien.Additionally, the court affirmed the district court's dismissal of Lin's counterclaims for bad faith and breach of contract. The court found no plausible claim supporting the argument that Hartford Accident unreasonably delayed settling Lin's claim. Lin's request for statutory penalties for Hartford Accident's purported delay in handling his claim was also denied.Finally, the court denied both parties' motions for sanctions. Lin's appeal was deemed frivolous in part, but the court exercised its discretion not to impose sanctions. View "Hartford Accident and Indemnity Company v. Lin" on Justia Law

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The Supreme Court of North Carolina reversed a decision by the Court of Appeals regarding the interpretation of a clause in the Financial Responsibility Act (FRA) about underinsured motorist (UIM) coverage. The defendant, Mr. Hebert, was in a vehicle accident where multiple parties were injured, and he sought to claim UIM coverage under his policy and his parents' policy. The Court of Appeals had allowed him to "stack" or add together the UIM limits from both policies to qualify his vehicle as underinsured. However, the Supreme Court disagreed with this interpretation.The court held that the FRA's plain language only permits the claimant’s UIM coverages that pertain to the vehicle involved in the accident, not all UIM policies for which the UIM claimant is personally eligible. Therefore, the defendant could not stack his policy’s UIM limits with his parents’ policy’s UIM limits to qualify his vehicle as underinsured. The court concluded that the defendant's vehicle did not qualify as an underinsured highway vehicle under the FRA, and he could not activate his policy’s UIM coverage. Consequently, the Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for entry of judgment on the pleadings in favor of the plaintiff, North Carolina Farm Bureau Mutual Insurance Company. View "N.C. Farm Bureau Mut. Ins. Co. v. Hebert" on Justia Law

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The United States Court of Appeals for the Second Circuit heard an appeal involving Timothy Daileader, the independent director and manager of an affiliated group of companies, collectively known as "Oaktree," which were in financial distress. Daileader was seeking coverage from his insurer, Certain Underwriters at Lloyds London Syndicate 1861 (Syndicate 1861), for his defense in litigation involving Oaktree. However, Syndicate 1861 denied Daileader’s insurance claim. Daileader subsequently sought a preliminary injunction to enforce Syndicate 1861’s duty to defend. The United States District Court for the Southern District of New York denied Daileader’s motion, and Daileader appealed.The Court of Appeals affirmed the district court's decision, finding that the district court did not abuse its discretion in denying Daileader's motion for a preliminary injunction. The court held that Daileader had not shown a clear or substantial likelihood of success on the merits of his claim. The court also found that Daileader had not made a strong showing of irreparable harm. The court concluded that the Syndicate's refusal to continue paying under its policy did not disrupt the status quo of ongoing payments between the two parties. Therefore, the court determined that Daileader's desired injunction was mandatory and not prohibitory, thus subject to a more stringent standard for relief. View "Daileader v. Certain Underwriters" on Justia Law