AIKG, LLC v. The Cincinnati Insurance Company

CourtDistrict Court, N.D. Georgia
DecidedSeptember 7, 2021
Docket1:20-cv-04051
StatusUnknown

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

Bluebook
AIKG, LLC v. The Cincinnati Insurance Company, (N.D. Ga. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

AIKG, LLC,

Plaintiff,

v. CIVIL ACTION FILE NO. 1:20-CV-4051-TWT

THE CINCINNATI INSURANCE

COMPANY,

Defendant.

OPINION AND ORDER This is a breach of contract action seeking insurance coverage for business losses related to the COVID-19 pandemic. It is before the Court on the Defendant’s Motion to Dismiss [Doc. 3]. For the reasons set forth below, the Court GRANTS the Defendant’s Motion to Dismiss [Doc. 3]. I. Background The Plaintiff AIKG, LLC operates an amusement business that offers indoor go-karting, video arcades, full-service dining, and other attractions at five locations in Georgia, Texas, and Florida. (Pl.’s Br. in Opp’n to Def.’s Mot. to Dismiss, at 5.) The Plaintiff purchased two property insurance policies (the “Policies”)—one for its Georgia and Texas locations and another for its Florida locations—from the Defendant Cincinnati Insurance Company. (Compl. ¶¶ 4– 5.) The Policies were in effect between June 1, 2019, and June 1, 2020, ( ) and T:\ORDERS\20\AIKG, LLC\mtdtwt.docx insured against “direct ‘loss’” to the Plaintiff’s property, which is defined as “accidental physical loss or accidental physical damage.” ( ¶¶ 57, 61.) In the event of a covered loss, the Policies provided Business Income, Extra Expense,

Extended Business Income, Civil Authority, Ingress and Egress, and Dependent Property coverage. ( ¶¶ 46–51.) There was no coverage exclusion for loss due to virus. ( ¶ 67.) The COVID-19 pandemic has upended the Plaintiff’s business. As the public health crisis rapidly unfolded across the United States in March 2020, state officials in Georgia, Texas, and Florida ordered non-essential businesses,

including restaurants and amusement operators, to cease in-person operations and later permitted them to reopen only under strict occupancy restrictions and sanitation requirements. ( ¶¶ 6–42.) Pursuant to these orders and health and safety concerns, the Plaintiff shut down all five of its locations on March 17, 2020. ( ¶ 7.) The Plaintiff then filed insurance claims under the Policies to recover financial losses stemming from the closures ( ¶ 92), but the Defendant denied coverage on the ground that COVID-19 and government-

mandated shutdowns had not caused direct physical loss or damage to the Plaintiff’s property. ( ¶¶ 93–94.) The Plaintiff initiated this action in the Superior Court of Cobb County, Georgia, on August 31, 2020, asserting three claims against the Defendant for breach of contract (Count I), statutory bad faith (Count II), and declaratory judgment (Count III). ( ¶¶ 95–107.) The Defendant removed the action to 2 T:\ORDERS\20\AIKG, LLC\mtdtwt.docx this Court pursuant to its diversity jurisdiction, 28 U.S.C. § 1332, as there is complete diversity of citizenship between the parties and the Plaintiff seeks to recover losses in excess of $75,000. (Notice of Removal ¶¶ 5–8.) The Defendant

now moves to dismiss all claims against it under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim for relief. (Def.’s Mot. to Dismiss, at 1.) II. Legal Standard A complaint should be dismissed under Rule 12(b)(6) only where it appears that the facts alleged fail to state a “plausible” claim for relief.

, 129 S. Ct. 1937, 1949 (2009); Fed. R. Civ. P. 12(b)(6). A complaint may survive a motion to dismiss for failure to state a claim even if it is “improbable” that a plaintiff would be able to prove those facts; even if the possibility of recovery is extremely “remote and unlikely.” , 550 U.S. 544, 556 (2007). In ruling on a motion to dismiss, the court must accept the facts pleaded in the complaint as true and construe them in the light most favorable to the plaintiff.

, 711 F.2d 989, 994–95 (11th Cir. 1983); , 40 F.3d 247, 251 (7th Cir. 1994) (noting the plaintiff “receives the benefit of imagination” at the pleading stage). Generally, notice pleading is all that is required for a valid complaint. , 753 F.2d 974, 975 (11th Cir. 1985), , 474 U.S. 1082 (1986). Under notice pleading, the plaintiff need 3 T:\ORDERS\20\AIKG, LLC\mtdtwt.docx only give the defendant fair notice of the plaintiff’s claim and the grounds upon which it rests. , 551 U.S. 89, 93 (2007). III. Discussion

In its motion to dismiss, the Defendant argues that the Plaintiff has not alleged sufficient facts to bring its financial losses within the Policies’ coverage. (Def.’s Br. in Supp. of Def.’s Mot. to Dismiss, at 1.) According to the Defendant, the Plaintiff’s allegations regarding the effects of COVID-19 on its business do not show “direct physical loss or damage to property,” “as required for any coverage under the plain language of the Polic[ies] and Georgia law.” (

(emphasis omitted).) The Plaintiff does not dispute that it must make this showing to obtain coverage; instead, it claims that it has sufficiently pleaded direct physical loss or damage in three ways: “1) COVID-19 is on AIKG’s business property; 2) COVID-19 is in its buildings; and 3) COVID-19 is a recurring threat to AIKG’s business, its employees, and its customers.” (Pl.’s Br. in Opp’n to Def.’s Mot. to Dismiss, at 3.) In the Plaintiff’s view, the presence of COVID-19 changes “property so that it is no longer safe to use,” “tak[ing]

what was a satisfactory piece of property and render[ing] it unsatisfactory[.]” ( at 6.) Therefore, the operative question is whether COVID-19 contamination causes direct physical loss or damage to property. But first, the Court must determine which state’s law to apply to this question. “Federal courts sitting in diversity apply the forum state’s choice-of-law rules”: in this case, Georgia. 4 T:\ORDERS\20\AIKG, LLC\mtdtwt.docx , 135 F.3d 750, 752 (11th Cir. 1998). Georgia “follows the traditional doctrine of : contracts are governed as to their nature, validity and interpretation by the

law of the place where they were made unless the contract is to be performed in a state other than that in which it was made.” (internal quotation marks and citation omitted). Here, the Policies were “made” in Georgia because they were delivered to the Plaintiff’s headquarters there. (Pl.’s Br. in Opp’n to Def.’s Mot. to Dismiss, at 16 n.5.)Further, the Policies are “to be performed” in Georgia, despite insuring some property in other states, because any

insurance payments would also be made to the Plaintiff’s Georgia headquarters. , 135 F.3d at 753. The Court thus applies Georgia law to this case. “In Georgia, insurance is a matter of contract, and the parties to an insurance policy are bound by its plain and unambiguous terms.” , 314 Ga. App. 110, 111 (2012) (punctuation and citation omitted). Construction of the policy's terms are questions of law:

The court undertakes a three-step process in the construction of the contract, the first of which is to determine if the instrument's language is clear and unambiguous.

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AIKG, LLC v. The Cincinnati Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aikg-llc-v-the-cincinnati-insurance-company-gand-2021.