Archive for the ‘Insurance Practices’ Category

Eastern District of Pennsylvania Finds No “Link” to Bad Faith in Excess Carrier’s Conduct Towards Sausage Company Insured

Thursday, September 25th, 2014

by Alice Ye, Sedgwick Chicago

This month, the Eastern District of Pennsylvania held that excess carrier American Guarantee and Liability Insurance Company (“American Guarantee”) did not engage in bad faith conduct towards insured Maglio Fresh Foods (“Maglio”), a sausage company. Charter Oak Ins. Co. v. Maglio Fresh Foods, Case Civil No. 12-3967, 2012 WL 4434715 (E.D. Pa. Sept. 9, 2014).

Maglio filed cross-claims against American Guarantee for statutory bad faith under 42 P.S.A. § 8371 and breach of the implied covenant of good faith and fair dealing. The claims were based on American Guarantee’s refusal to post a supersedeas bond for Maglio so that Maglio could appeal an adverse judgment entered in the underlying action. Maglio argued that, as the primary carrier had already tendered its policy limits to the court, the primary limits were exhausted and American Guarantee’s duty to defend, including the duty to post the appellate bond, was triggered. In contrast, American Guarantee argued that, under the terms of its “follow form” policy, it had no duty to defend until the primary carrier exhausted its limits through payment for a covered claim. American Guarantee argued that only one out of the two claims in the underlying action was covered (the “Forte brand claim”). American Guarantee previously disclaimed coverage for the other claim (the “Maglio brand claim”). As the value of the covered Forte brand claim was less than the primary policy limit, the primary carrier’s payment of that claim did not exhaust the policy. American Guarantee further contended that the primary carrier’s payment of an additional $440,000 into the court was a “voluntary payment” that did not exhaust the primary policy.

The court found in favor of American Guarantee, holding that “Maglio has failed to prove, by the applicable standard of proof, clear and convincing evidence, that American Guarantee is liable for statutory bad faith, because the evidence does not show any conduct that meets the Pennsylvania legal standard for statutory bad faith, and certainly no conduct that would warrant punitive damages, under Pennsylvania law.” The court further held that its “analysis of the common law bad faith claim, arising out of the contractual relationship … leads to the same conclusion.”

With respect to its disclaimer of coverage, the court held that “Maglio has not brought forth evidence that American Guarantee’s conduct lacked a reasonable basis.” Rather, American Guarantee’s “vigilance” (including (1) conducting a reasonable investigation, (2) justifiably relying on the primary carrier’s denial of coverage of the Maglio brand claim and the primary carrier’s commitment to continue to defend the claim, and (3) hiring coverage counsel to monitor the underlying action), coupled with the primary carrier’s continued defense of Maglio, relieved American Guarantee of having to take any action in the defense. Moreover, the court held that, even if American Guarantee incorrectly evaluated coverage for the Maglio brand claim, “the evidence fails to show that American Guarantee did so out of self-interest or ill will.” The court found that, “[a]bsent such a showing, Maglio’s bad faith claim falls short.”

The court also determined that, as the verdict for the covered Forte brand claim was only $660,000, it did not exhaust the primary policy limits, and thus concluded that the primary insurer’s payment “did not trigger American Guarantee’s duty to defend, and therefore, its duty to post an appellate bond.” As a result, “American Guarantee did not act in bad faith by refusing to post such bond.”

New Jersey Court Turns the Screws on the Insured, Holding That “Your Product” Exclusion Bars Coverage For Defective Product Claim

Thursday, September 11th, 2014

By Julie Kim, Sedgwick New York

In Titanium Industries, Inc. v. Federal Ins. Co., No. A-1922-12T1, 2014 WL 4428324 (N.J. Super. Ct. App. Div. Sept. 10, 2014), the court held that the commercial general liability policy issued by defendant Federal Insurance Company (“Federal”) to Titanium Industries, Inc. (“TII”) did not provide coverage for TII’s claim based on the policy’s “Your Product” exclusion.

TII manufactured and supplied titanium products, and sold titanium bars to Biomet Manufacturing Corp. (“Biomet”), pursuant to the parties’ long-term supply agreement. Biomet, a manufacturer of orthopedic implants and devices, used TII’s product to manufacture screws that were incorporated into its products. Biomet’s screws were composed entirely of TII’s titanium. After Biomet alerted TII to defects in its titanium bars which undermined the strength of the products manufactured using the screws, Biomed recalled certain affected products. TII and Biomed settled Biomed’s claim, and TII sought defense and indemnification from Federal.

On motions for summary judgment, the trial court ruled in favor of Federal on its motion, and against TII on its motion. The Appellate Division affirmed that ruling, relying on prior decisions by New Jersey state courts. The court noted that an insured bears the risk of its own faulty work, which is a matter of warranty and not insurance coverage. The court determined that the policy would not provide coverage for the claimed loss, which was based solely upon the defective titanium supplied by the insured in contravention of the express warranties made in the parties’ long-term supply agreement. The insured’s titanium was fashioned into screws, as contemplated by the parties’ long-term supply agreement, and the titanium was otherwise unaltered and not appended to other property that was damaged. Thus, the court concluded that Biomet’s claims were for TII’s breach of its warranties regarding the intended use of its product, and the risk of replacement or repair of its faulty goods was the cost of doing business, and was not a risk passed on to Federal. The court further noted that even if the claim fell within the policy’s insuring agreement, coverage was precluded by the policy’s “your product” exclusion, which excluded coverage for “property damage to your product arising out of it or any part of it,” where “your product” was defined to include “goods or products . . . manufactured, sold, handled, distributed or disposed by” the insured, and included “representations or warranties made at any time with respect to the durability, fitness, performance, quality or use of” the insured’s titanium.

 

First Circuit Confirms No Fiduciary Breach in Use of a Retained Asset Account

Wednesday, September 10th, 2014

By Erin Cornell, Sedgwick San Francisco

For the second time this summer, the First Circuit Court of Appeals addressed whether an ERISA fiduciary’s use of a retained asset account (“RAA”) to pay death benefits is a breach of fiduciary duty.  In Merrimon v. Unum Life Ins. Co., 758 F.3d 46 (1st Cir. 2014), the First Circuit held that an insurer acting as a plan administrator properly discharges its duties under ERISA when it pays a death benefit through a RAA, provided that the method of payment is set forth in the plan document.  Eight weeks later, in Vander Luitgaren v. Sun Life Assur. Co. of Canada, Case No. 13-2090, 2014 WL 4197947 (1st Cir. Aug. 26, 2014), the First Circuit again addressed an administrator’s use of a RAA to pay death benefits pursuant to the terms of an ERISA plan.  The court found that Vander Luitgaren could be decided on the basis of its opinion in Merrimon, but it wrote separately to address additional issues not present in Merrimon. 

In Vander Luitgaren, the appellant was a beneficiary of an ERISA-governed life insurance plan.  The insurer, Sun Life, paid the beneficiary the full amount of benefits owed, and placed the entirety of the funds ($151,000) into a RAA, which earned interest for the beneficiary at 2% per year.  The beneficiary had the right to withdraw all or any part of the funds at any time, provided that no withdrawal could be for less than $250.  Sun Life would close the RAA if the balance fell below $250, in which event the beneficiary would receive the balance.  Within a matter of days, the beneficiary withdrew the entire $151,000.  Sun Life then closed the account and mailed him a check for $74.48 in interest. 

The beneficiary then sued Sun Life, contending that its use of the RAA breached its fiduciary duties.  The district court granted Sun Life’s motion for summary judgment, and the beneficiary appealed.  Sun Life challenged his statutory standing, an issue not raised in Merrimon, arguing that because he received the full amount of the death benefit when the sum was credited to the RAA, he was no longer entitled to a benefit under the plan and therefore lacked standing to sue under ERISA.  The court declined to decide this issue and instead resolved the dispute on the merits.  Unlike Merrimon, the plan applicable in Vander Luitgaren did not expressly provide that benefits would be paid via a RAA.  Rather, the plan provided, “[t]he Death Benefit may be payable by a method other than a lump sum.  The available methods of payment will be based on the benefit options offered by Sun Life at the time of election.”  Nevertheless, the court found that this was a distinction without a difference – Sun Life did not breach its fiduciary duties because establishment of a RAA was among the payment options offered by Sun Life, the beneficiary had immediate and unrestricted access to the entire death benefit, and ERISA gives plan sponsors considerable latitude to set the terms of a plan.  The First Circuit thus affirmed the district court’s judgment in favor of Sun Life.

 

In California, Looks Really Do Matter: Visual Appearance and Internal Consistency of Policy Language Supports Application of Exclusion

Friday, September 5th, 2014

By Kimberly K. Jackanich, Sedgwick San Francisco

In Yu v. Landmark American Ins. Co., 2014 WL 4162365 (Cal. Ct. App. Aug. 22, 2014)*, the California Court of Appeals relied on the visual appearance and internal consistency of an endorsement entitled “EXCLUSION – YOUR PRIOR WORK” to find that the endorsement precluded coverage for construction defect claims asserted against a subcontractor for work performed over a year before the policy’s inception.

Yu, a developer, entered into a contract with a general contractor for the construction of a hotel.  The general contractor then entered into a subcontract with C&A Framing Company (“C&A”), but fired C&A before it had completed all of the work required by the subcontract. After May 2003, C&A never returned to the construction site.

Landmark American Insurance Company (“Landmark”) issued C&A a commercial general liability policy for the period of September 18, 2004 to September 18, 2005.  The policy contained an endorsement entitled “EXCLUSION – YOUR PRIOR WORK,” which provided that the insurance did not apply to bodily injury, property damage, or personal and advertising injury arising out of C&A’s work prior to 9/18/04.

In 2004, the developer sued C&A for alleged construction defects, and C&A tendered its defense to Landmark.  The insurer declined the tender on the basis of the Your Prior Work Exclusion and the Policy requirement that the outset of damage occur during the policy period.  Although C&A did not dispute the declination, the developer brought suit against Landmark and other insurers, alleging that C&A had assigned to her all rights against any insurer.  The developer argued that Landmark could not rely on the prior work exclusion because it was ambiguous and should be construed in favor of coverage.  The developer also argued that Landmark had failed to consider certain facts when denying coverage.  Specifically, the developer argued that the language of the prior work exclusion could be construed to modify the term “property damage,” such that property damage rather than prior work was excluded.

Rejecting the developer’s arguments, the court found that the heading of the endorsement, set out in all caps and boldface type, was prominent, clear, explicit and did not require any technical interpretations.  Finding that the developer’s interpretation was not objectively reasonable, the court also relied on the exclusion for pre-existing damage or injury to conclude that the plaintiff’s interpretation would be “wholly redundant and constitute surplusage” if the prior work exclusion was interpreted to preclude prior property damage.  Based on the clear application of the prior work exclusion, the court also rejected all of the developer’s arguments regarding Landmark’s failure to properly investigate or defend the matter.

The court’s holding in Yu is an important reminder for insurers regarding the visual appearance and internal consistency of their policies.  The court’s reliance on the caps and boldface type as well as the title of the “YOUR PRIOR WORK” exclusion illustrates the significance of carefully crafted and visually clear policy headings.  Further, the court’s secondary support in the policy’s pre-existing damage exclusion reinforces that courts will interpret the policy as a whole.  Thus, when limiting and exclusionary language is internally consistent, insureds will face an uphill battle in their efforts to broadly construe policy language for purposes unintended by the insurers.

 

*The opinion is unpublished

District Courts Reviewing ERISA Cases Under the Arbitrary and Capricious Review Standard Serve Only in an Appellate Role

Wednesday, August 27th, 2014

By Matthew P. Mazzola, Sedgwick New York

In McCorkle v. Metro. Life Ins. Co., 13-30745, 2014 WL 2983360 (5th Cir. 2014), the Fifth Circuit reversed the district court’s holding that MetLife’s adverse determination regarding the plaintiff’s claim for benefits due to the death of her husband (the “decedent”) under his employer’s Accidental Death and Dismemberment Plan (the “Plan”) was arbitrary and capricious. MetLife funded benefits and administered claims under the Plan pursuant to a full grant of discretionary authority. In her motion for summary judgment, the plaintiff challenged MetLife’s finding that the decedent’s death was both not “accidental” and subject to the Plan’s exclusions for self-inflicted injuries and suicide. The district court granted plaintiff summary judgment finding that her explanation of the decedent’s death was “more reasonable” than MetLife’s final determination that his death was the result of suicide.

The Fifth Circuit criticized the district court’s application of the arbitrary and capricious review standard, holding that in reviewing denied claims for benefits under this deferential standard, district courts:

are not sitting, as they usually are, as courts of first impression. Rather, they are serving in an appellate role.  And, their latitude in that capacity is very narrowly restricted by ERISA and its regulations, as interpreted by the courts of appeals and the Supreme Court, including the oft-repeated admonition to affirm the determination of the plan administrator unless it is “arbitrary” or is not supported by at least “substantial evidence”—even if that determination is not supported by a preponderance.

The Fifth Circuit also held that MetLife was only required to base its determination on substantial evidence, which means “more than a scintilla, less than preponderance, and such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Based on its review of the plaintiff’s claim under the appropriate standard of review, the Fifth Circuit reversed the district court’s decision finding that MetLife’s determination was, in fact, based on substantial evidence. In addition, the Fifth Circuit held that the district court erred in holding that plaintiff’s explanation of the decedent’s death  was “more reasonable” because this type of analysis improperly “constitutes finding the “‘preponderance,’ which has no place in this ERISA review.” Lastly, the Fifth Circuit held that the district court erred in disregarding MetLife’s deference by improperly substituting its own narrow interpretation of the term “suicide” for MetLife’s reasonable interpretation of that term.

 

You May Have Stolen the Advertising Database, But You Still Have No Advertising Idea

Thursday, August 21st, 2014

By Daniel Pickett, Sedgwick New York

In Liberty Corporate Capital Ltd. v. Security Safe Outlet, 2014 WL 3973726 (6th Cir. August 15, 2014), the Sixth Circuit Court of Appeals held that where a stolen customer database is used as the basis of an advertising campaign, a claim arising from the misappropriation of that database does not constitute an advertising injury.

The case arose from an action brought by BudsGunShop.com, LLC (“BGS”) against a competitor, Security Safe Outlet, Inc. (“SSO”), and its former employee Matthew Denninghoff. While still a BGS employee, Denninghoff conspired with his sister, who was SSO’s Vice President, to open an internet firearms sales operation for SSO, in competition with BGS.  When Denninghoff left BGS, he secretly took a number of backup copies of BGS’s customer database with him. These were used by SSO to send mass promotional emails to BGS’s Kentucky customers. Although BGS directed SSO to desist in its use of the customer information, SSO refused to do so. BGS then sued SSO.

SSO sought a defense from its insurer, Liberty Corporate Capital Limited (“Liberty”), under a series of commercial general liability policies. SSO argued that coverage for BGS’s misappropriation of trade secrets claim fell within the policies’ adverting injury coverage, because the mass promotional emails were “advertisements,” and BGS’s claim constituted an allegation that SSO improperly used BGS’s “advertising idea” in its advertisements.  Liberty denied coverage arguing that, although the emails may have been “advertisements,” BGS’s misappropriation claim was not covered because BGS did not allege that SSO or Denninghoff used any of its “advertising ideas” in the emails, and the customer database itself was not an “advertising idea.”

The Sixth Circuit agreed with Liberty.  BGS’s allegations regarding misappropriation and use of the customer database did not involve the use of an “advertising idea,”  which was “reasonably understood to encompass a company’s plan, scheme, or design for calling its products or services to the attention of the public.”   BGS had not alleged that SSO used any of its advertising plans, schemes, or designs in the emails, only that customer information was used as a basis for the advertising campaign.

The Sixth Circuit affirmed the district’s court’s holding that Liberty had no duty to defend or indemnify SSO.

Insured Not Justified in Ignoring Claims-Made-and-Reporting Requirements

Friday, August 8th, 2014

By Beth Yoffie, Sedgwick Los Angeles

An insured’s attempt to circumvent the claims-made-and-reporting requirements of its professional liabilty policy, by arguing that the doctrine of promissory estoppel applied, was thwarted when a court ordered summary judgment in favor of the insurer on grounds that there was no clear and unambiguous promise by the insurer, and no justifiable reliance by the insured.  Hamman-Miller-Beauchamp-Deeble, Inc. v. Liberty Mutual Agency Corp., United States District Court, C.D. California, No. CV 13-07129-RGK (VBKx) (July 7, 2014).

Plaintiff Hamman-Miller-Beauchamp-Deeble, Inc. (HMBD), an insurance broker, received two letters in 2010 from an attorney claiming that his client had sustained damages as a result of HMBD’s negligence.  The attorney asserted that HMBD improperly advised the client that a health insurance policy it sold her would cover treatment from a non-contracted provider.  HMBD waited until it was served with a lawsuit two years later to provide notice of the claim to its Insurance Professionals Errors and Omissions Liability insurer.  General Insurance Company of America (General) denied coverage on the basis that (1) HMBD was aware of the accusation of negligent services prior to the inception of the policy; and (2) the claim was not both made against and reported by HMBD while the policy was in effect. HMBD sued General for breach of contract, bad faith and promissory estoppel.

In opposing General’s summary judgment motion, HMBD argued that the demand letters did not constitute a “Claim” triggering its duty to report.  The Court disagreed. First, the letter informed HMBD that it was “legally responsible for … damages” and thus contained a demand for damages. It also informed HMBD that the damages were the result of “negligence” and, therefore, alleged a wrongful act arising out of HMBD’s services.  The Court further found that, even if the letters were not “Claims,” the Policy would not provide coverage because HMBD knew of the wrongful act giving rise to the lawsuit and/or had a basis to reasonably anticipate that the lawsuit would be filed before the policy incepted. 

In its promissory estoppel claim, HMBD asserted that, in handling a different HMBD claim in 2008,  General’s claim representative told HMBD’s president that “he probably didn’t have to put General on notice of the Temple matter unless and until a lawsuit was filed.”   The Court found the alleged statement did not constitute a clear and unambiguous promise supporting promissory estoppel.  It also found that HMBD’s reliance on the alleged statement was unjustified as a matter of law when the parties entered a new insurance contract with contrary terms.

Prior Publication Precludes Coverage for Advertising Injury

Wednesday, July 23rd, 2014

By Daniel Bryer, Sedgwick New York

In Street Surfing, LLC v. Great American E&S Ins. Co., 752 F.3d 853 (9th Cir. 2014), the court held that the prior publication exclusion precluded coverage to Street Surfing, LLC (“Street Surfing”) for an underlying lawsuit alleging Street Surfing improperly used a third party’s advertising idea.

Great American E&S Insurance Company (“Great American”) issued two consecutive general liability policies to Street Surfing covering personal and advertising injury liability.  The policies specifically excluded (i) prior publication, (ii) copyright and trademark infringement (the “IP Exclusion”) and (iii) advertising injury arising out of any actual or alleged infringement of intellectual property rights (the “AI Exclusion”).

In June 2008, Street Surfer was sued by Ryn Noll (“Noll”), who owned the registered trademark “Streetsurfer,” claiming trademark infringement, unfair competition and unfair trade practices under federal and California law.  Street Surfer submitted a claim for coverage to Great American and tendered Noll’s complaint.  Great American denied coverage, citing the IP Exclusion and the AI Exclusion.

Street Surfer brought a declaratory judgment against Great American seeking defense and indemnification for the Noll action.  Affirming the district court, the Ninth Circuit held that the prior publication exclusion relieved Great American of its duty to defend Street Surfing in the Noll action because the extrinsic evidence available to Great American at the time of tender conclusively established: (1) that Street Surfing published at least one advertisement using Noll’s advertising idea before coverage began; and (2) that the new advertisements Street Surfing published during the coverage period were substantially similar to that pre-coverage advertisement.

The policies’ prior publication exclusion exempted from coverage “‘[p]ersonal and advertising injury’ arising out of oral or written publication of material whose first publication took place before the beginning of the policy period.”  The straightforward purpose of this exclusion, the court ruled, was to “bar coverage” when the “wrongful behavior . . . beg[a]n prior to the effective date of the insurance policy.”

In the context of advertising injury coverage, an allegedly wrongful advertisement published before the coverage period triggers application of the prior publication exclusion, barring coverage of injuries arising out of re-publication of that advertisement, or any substantially similar advertisement, during the policy period, because such later publications are part of a single, continuing wrong that began before the insurance policy went into effect.

The test, then, is whether reuse “of substantially the same material” occurred.  In making this determination, the court focused on the relationship between the alleged wrongful acts “manifested by those publications,” holding that a “post-coverage publication is ‘substantially similar’ to a pre-coverage publication if both publications carry out the same alleged wrong.”  Focusing on the alleged wrongful acts fulfills the prior publication exclusion’s purpose of barring coverage when “the wrongful behavior had begun prior to the effective date of the insurance policy.”

Federal Court Undresses Urban Outfitters in Personal and Advertising Injury Coverage Dispute

Thursday, July 3rd, 2014

By Ira Steinberg, Sedgwick Los Angeles

In OneBeacon America Ins. Co. v. Urban Outfitters Inc., 2014 WL 2011494 (E.D.Pa. 2014), the Eastern District of Pennsylvania analyzed the application of “personal and advertising injury” coverage to alleged violations of consumer confidentiality statutes and, in ruling in favor of the insurers, found that the claims did not come within the policy’s insuring agreement or were otherwise excluded.

The coverage case concerned three underlying cases alleging that Urban Outfitters and Anthropologie illegally collected customers’ zip codes when processing credit card transactions.  Urban Outfitters and Anthropologie were covered by policies that insured them against claims of, among other things, “personal and advertising injury” which includes “oral or written publication, in any manner, of material that violates a person’s right to privacy.”  However, under Pennsylvania law the only type of invasion of privacy which is covered under the insuring agreement is the breach of a person’s “right to secrecy.”  The policies also contained an exclusion for “Personal and advertising injury” arising out of a violation of any “statute, ordinance or regulation…that addresses, prohibits, or limits the … dissemination, … collection, recording, sending, transmitting, communicating or distribution of material or information.”

The court analyzed three underlying claims to determine if the duty to defend was triggered with respect to any of them. The first claim, the Hancock Action, alleged that the insureds collected zip codes from customers when processing credit card transactions and transmitted the zip codes to corporate headquarters for use in marketing campaigns. The court held that this action did not come under the insuring agreement because the transmission of the zip code information to corporate headquarters did not constitute a “publication.”  Since the insuring agreement requires an “oral or written publication” and there was no third-party dissemination that could constitute a publication, there was no coverage for the Hancock Action. However, the second claim, the Dremak Action, did involve a publication because it alleged that the zip code information was sold and disseminated to third parties in violation of the Song-Beverly Credit Card Act of 1971.  Although the court held that the personal and advertising injury insuring agreement was triggered, it also held that the exclusion for claims arising out of the violation of a statute addressing the handling of information applied and, therefore, the claim was excluded. 

Lastly, the third claim, the Miller Action, alleged the insured collected zip codes with credit card transactions, and used that information to send mail advertising to its customers.  The court held that sending junk mail to a customer did not invade their right to secrecy, and because the personal and advertising injury insuring agreement only covered violations of the right to secrecy, there was no coverage for the claim.  Accordingly, the court granted summary judgment in favor of the insurers.

 

 

Hawaii and Massachusetts Governors Sign Legislation Extending Statute of Limitations for Abuse Claims

Tuesday, July 1st, 2014

By Cathy Sugayan and Serena Lee, Sedgwick Chicago

There has been legislation considered for claims arising out of childhood sexual abuse that would extend the limitations periods or allow pursuit of claims that were otherwise time-barred. For example, on June 23, 2014, Hawaii’s governor signed legislation into law extending a “window” allowing previously time-barred claims to be brought until April 24, 2016.  On June 26, 2014, Massachusetts’ governor signed legislation into law extending the limitations period.  Also, this past year, the following other states have considered legislation to extend the limitations periods for childhood sexual abuse: California, Georgia, Iowa, Missouri, New York, Pennsylvania, and Wisconsin; some of these efforts have already failed to pass into law and a couple may bring sweeping changes.

For our readers who are involved in insuring public and private entities against sexual abuse claims, these are important developments that could impact the defense of and coverage for these types of claims.  The Sedgwick white paper provides a survey of the current law and legislation regarding the statute of limitations for claims arising from childhood sexual abuse.

 

 

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