28th Street Superior Hospitality Inc v. The Cincinnati Insurance Company

CourtDistrict Court, N.D. Indiana
DecidedFebruary 15, 2022
Docket1:19-cv-00511
StatusUnknown

This text of 28th Street Superior Hospitality Inc v. The Cincinnati Insurance Company (28th Street Superior Hospitality Inc v. The Cincinnati Insurance Company) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
28th Street Superior Hospitality Inc v. The Cincinnati Insurance Company, (N.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

28th STREET SUPERIOR HOSPITALITY, ) INC., ) ) Plaintiff, ) ) v. ) Cause No. 1:19-CV-511-HAB ) THE CINCINNATI INSURANCE ) COMPANY, ) ) Defendant. )

OPINION AND ORDER

The insurance policy issued by Defendant to Plaintiff provides that, if a loss occurs, Defendant will only pay the lesser of the appraised value of the loss or the amount Plaintiff spent repairing. The issue before the Court is a simple one: must Plaintiff document the exact amount it spent on repairs? Believing that Plaintiff must, Defendant has refused to pay anything more than the actual cash value (“ACV”) for a fire loss it insured. Plaintiff believes Defendant’s refusal is a breach of the policy and a breach of the duty of good faith. The Court finds no support for Defendant’s expansive reading of its own policy, either in the policy itself or the case law. What’s more, Defendant has no evidence, other than its “beliefs,” that Plaintiff paid less than the appraised value of the loss. Because Plaintiff has designated undisputed evidence that it did spend more on repairs than the appraised value, it is entitled to summary judgment on its breach of contract claim. Whether Defendant’s breach was in bad faith is an issue for a jury.1

1 Defendant also filed a Motion to Strike (ECF No. 37). Because the Court can distinguish which exhibits, affidavits, and statements may properly be considered when deciding whether summary judgment is appropriate, the Court denies the motion. The Court has noted the Defendant’s objections and has considered the objections when they arose in the I. Factual Background In November 2015, a fire occurred at a Fort Wayne hotel owned by Plaintiff (“Property”). The Property was insured by Defendant under Policy No. INN 000 04 01 with effective dates of January 2013 through January 2016 (“Policy”). Plaintiff reported the loss to Defendant the day after the fire.

At the beginning of April 2016, Plaintiff made a formal claim for payment under the Policy. The claim asserted an ACV of $2,474,177.78 and a replacement cost value (“RCV”) of $2,647,855.97. Defendant, through a third-party adjuster, rejected Plaintiff’s claim six weeks later. Defendant placed the ACV at $1,288,191.782 and the RCV at $1,493,415.74. Given the large gap in the parties’ estimates, Plaintiff invoked the Policy’s appraisal provision in June 2016. That provision provided: If we and you disagree on the value of the property, the amount of Net Income and operating expense, or the amount of “loss”, either may make written demand for an appraisal of the “loss”. In this event, each party will select a competent and impartial appraiser. The two appraisers will select an umpire. If they cannot agree, either may request that selection be made by a judge of a court having jurisdiction. The appraisers will state separately the value of the property, the amount of Net Income and operating expense, and the amount of “loss”. If they fail to agree, they will submit their differences to the umpire. A decision agreed to by any two will be binding.

(ECF No. 40-1 at 52). Plaintiff also submitted a sworn proof of loss, showing an ACV of $2,631,049.80 and an RCV of $2,804,728.49. The appraisal process concluded in May 2017 with an appraisal award. The award determined the ACV of the loss to be $2,053,797.35 and the RCV to be $2,283,417.65. The parties

Court’s summary judgment analysis. The Court also notes that, in reaching its summary judgment conclusions, it did not rely on any of the materials that formed the basis for Defendant’s objection.

2 Plaintiff did not receive a check for this ACV amount until late November 2016. refer to the difference between these numbers as “recoverable depreciation.” Defendant issued a check for $765,615.57, the difference between its ACV calculation and the appraisal award, four days after the award was entered. Almost one year later, Plaintiff advised Defendant that repairs on the Property had been completed. Plaintiff submitted forty-seven (47) checks, which it claimed showed payments for the

repairs, totaling more than the appraised RCV. The checks came with a waiver of lien from Plaintiff’s contractor in the same amount. Plaintiff demanded payment of the recoverable depreciation under the Policy’s RCV loss payment provision which provided: e. We will not pay more for “loss” on a replacement cost basis than the least of:

(1) The Limit of Insurance applicable to the lost or damaged property;

(2) The cost to replace, on the same “premises”, the lost or damaged property with other property;

(a) Of comparable material and quality; and

(b) Used for the same purpose; or

(3) The amount you actually spend that is necessary to repair or replace the lost or damaged property.

(Id. at 58) (hereinafter the “RCV loss payment provision”). The parties agree, generally, that the appraised RCV is the subsection (2) amount. Defendant rejected Plaintiff’s payment demand. Unsatisfied with the lack of specificity on the checks or the lien waiver, Defendant asked Plaintiff to provide “corresponding itemized invoices,” “the contractor’s itemized draw requests and any other available documentation to support that these payments were for repairs allotted under this claim.” (ECF No. 29-2 at 23). Defendant’s primary concern, it seems, was that the amounts reflected in the checks and waiver of lien were, at least in part, payment for other work done to the Property. In response, Plaintiff stated that it did not have the requested documents and that Plaintiff had “provided [Defendant] the only documentation available to [Plaintiff].” (Id. at 24). With no documentation forthcoming, Defendant asked to inspect the Property to verify the repairs. Defendant inspected the Property twice in May 2018.3 After those inspections, Defendant’s Field Claims Superintendent, Corey Linder (“Linder”) told his superiors that “all

repairs were completed,” though he did note “several changes . . . along with a number of upgrades throughout the building.” (ECF No. 32-3 at 28). Linder also told his superiors that Defendant had paid a previous wind damage claim to the Property based on “similar documents” and an inspection. (Id.). Just days after the second inspection, Plaintiff again demanded payment of the recoverable depreciation. This time it included a letter from the appraisal umpire, Steven Morris (“Morris”), in which Morris contended that Plaintiff need only provide “proof of completion of repairs and proof of payment incurred to make those repairs in order to make claim for the withheld depreciation.” (Id. at 35). Defendant again declined, stating that it was “unable to determine if any replacement

cost payment is due because the information provided to date is too vague and incomplete.” (Id. at 37). Instead of additional documents, Defendant requested a “thorough inspection” of the Property. (Id. at 38, 39, 41). Defendant anticipated the inspection would take “2-3 hours” and requested that Plaintiff’s contractor be present. (Id.). Plaintiff refused Defendant’s request for another inspection, noting that Plaintiff “has twice provided [Defendant’s] consultants full access to the” Property. (Id. at 42). Plaintiff continued to assert that the documentation it provided was enough, and again demanded payment of the recoverable depreciation. This refusal prompted Defendant to “deny any payment for the

3 It appears from the correspondence that Defendant asked Plaintiff’s contractor to be present during the inspections. That did not occur. And Defendant had limited access to the Property during the first inspection. eNO OI ES OS EEE II ESE IED

replacement cost of the” Property.” (/d. at 44).

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28th Street Superior Hospitality Inc v. The Cincinnati Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/28th-street-superior-hospitality-inc-v-the-cincinnati-insurance-company-innd-2022.