Am. Prop. Cas. Ins. Ass'n v. Kreidler

CourtWashington Supreme Court
DecidedDecember 8, 2022
Docket100,095-2
StatusPublished

This text of Am. Prop. Cas. Ins. Ass'n v. Kreidler (Am. Prop. Cas. Ins. Ass'n v. Kreidler) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Am. Prop. Cas. Ins. Ass'n v. Kreidler, (Wash. 2022).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON DECEMBER 8, 2022 IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON DECEMBER 8, 2022 ERIN L. LENNON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

AMERICAN PROPERTY CASUALTY ) INSURANCE ASSOCIATION, on behalf of ) No. 100095-2 its Washington-licensed members, ) ) Petitioners, ) ) v. ) En Banc ) MIKE KREIDLER, the elected Insurance ) Commissioner for the State of Washington, ) ) Respondent. ) Filed: December 8, 2022 _______________________________________)

MADSEN, J.—Pursuant to RCW 48.04.010(5), American Property Casualty

Insurance Association (Association) requested an adjudicative hearing before an

administrative law judge (ALJ) rather than the insurance agency’s in-house presiding

officer. The request was denied. The Association now seeks a writ of mandamus

against Insurance Commissioner Mike Kreidler, requiring him to transfer the hearing.

The Association could have sought judicial review by way of the Administrative

Procedure Act (APA), ch. 34.05 RCW, thus, the Association fails to demonstrate it has

“no plain, speedy, and adequate remedy” at law, one of the three requirements for a writ For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 100095-2

to issue. Seattle Times Co. v. Serko, 170 Wn.2d 581, 588-89, 243 P.3d 919 (2010); RCW

7.16.170, .360. Accordingly, we dismiss the petition.

BACKGROUND

The material facts of this case are undisputed. On June 25, 2021, Commissioner

Kreidler issued a data call to 123 property and casualty insurers operating in this state.

The call asked for claim information on private passenger automobile insurance coverage

provided from 2016 to 2020: details on refunds, credit, or reductions provided to

policyholders in 2020 relating to COVID-19 (Coronavirus disease 2019), and certain

quarterly financial data. Commissioner Kreidler noted that the call was different from

previous requests because the responsive information would be public and

nonconfidential. The due date for the information was set for July 30, 2021.

On July 16, 2021, the Association objected to the data call and demanded an

administrative hearing on behalf of its Washington members. The demand letter alleged

that the commissioner’s data call exceeded his statutory and regulatory authority, and was

therefore invalid. The Association also asserted that the data call and the enforcement

action against Association members were automatically stayed under RCW 48.04.010(1),

and it invoked RCW 48.04.010(1)(b) and (5) to request a hearing before an ALJ.

On July 19, the Office of the Insurance Commissioner’s (OIC) hearing unit

confirmed by e-mail that it had received the hearing demand and informed the parties that

a stay of the data call was in place. That same day, one of the Association’s attorneys

contacted the insurance commissioner’s designee, Presiding Officer Julia Eisentrout,

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 100095-2

asking if the matter would be transferred to an ALJ. The presiding officer responded,

also via e-mail, that transfer to an ALJ was not required under RCW 48.04.010(5) and

(6), and that the OIC’s policy was to transfer matters potentially affecting the status of a

license to an ALJ but to retain for internal resolution all other matters. Because

Association members were not issued OIC licenses, the proceeding would not be

transferred.

The next day, July 20, the OIC attorney assigned to the matter e-mailed the parties

and the presiding officer, addressing whether the Association members were “licensees,”

disagreeing that an automatic stay applied, and questioning whether the Association had

standing. The OIC attorney asked for the opportunity to brief the issues. Association

lawyers immediately stated that the OIC attorney had engaged in premature briefing

without leave and declined to answer. The presiding officer explained to the parties on

July 21 that the matter would remain within the OIC and that she did not believe the OIC

was “precluded from objecting to the stay or raising the issue regarding [Association]

members.” Clerk’s Papers at 48.

Before the presiding officer weighed in on OIC’s standing concerns, the

Association filed for reconsideration of the e-mail ruling or, in the alternative, a stay of

proceedings pending appeal to superior court. On August 12, 2021, the presiding officer

denied both, concluding in a written order that the presiding officer’s decision to deny

transfer to an ALJ was not a final order and reconsideration was not available, and that

Association member insurers were not “licensees,” and thus were not entitled to an ALJ

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 100095-2

hearing. The denial of the stay to seek review in superior court did not affect the stay of

the data call, which remained in place—staying the deadlines to respond for Association

members and preventing publication of any information provided to the OIC from

members under the call.

In response, the Association filed the instant petition for a writ of mandamus

against the insurance commissioner, seeking to compel him to transfer the hearing to an

ALJ pursuant to RCW 48.04.010(5).

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Am. Prop. Cas. Ins. Ass'n v. Kreidler, Counsel Stack Legal Research, https://law.counselstack.com/opinion/am-prop-cas-ins-assn-v-kreidler-wash-2022.