American Southern Insurance Company v. Spn Trans, LLC.

CourtCourt of Appeals of Georgia
DecidedJune 15, 2021
DocketA21A0174
StatusPublished

This text of American Southern Insurance Company v. Spn Trans, LLC. (American Southern Insurance Company v. Spn Trans, LLC.) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Southern Insurance Company v. Spn Trans, LLC., (Ga. Ct. App. 2021).

Opinion

FIRST DIVISION BARNES, P. J., GOBEIL and MARKLE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

June 3, 2021

In the Court of Appeals of Georgia A21A0174. AMERICAN SOUTHERN INSURANCE COMPANY GO-007 v. SPN TRANS, LLC. et al.

GOBEIL, Judge.

American Southern Insurance Company (“ASIC”) filed a petition for

declaratory judgment in the trial court seeking a determination as to whether it was

responsible for providing insurance coverage for a motor vehicle accident. Following

a bench trial, the trial court found as a matter of law that at the time of the accident

the truck driven by ASIC’s insured was being used for personal reasons, and thus,

ASIC was responsible for coverage for the accident under its non-trucking policy.

ASIC now appeals, arguing that the trial court erred by: (1) failing to properly

interpret the unambiguous language contained in the non-trucking policy to find that

routine maintenance to the truck constitutes a business use; (2) ignoring this Court’s prior decisions, which define when a truck driver’s actions are considered to be part

of their trucking business versus for personal use; (3) ignoring the applicable federal

regulations, which state that transporting a truck for maintenance does not constitute

a personal use; (4) failing to consider the policy implications of its ruling on

Georgia’s trucking and insurance law; and (5) applying inadmissible evidence to its

judgment. For the reasons that follow, we affirm.

On an appeal from an entry of judgment following a bench trial, we apply a de novo standard of review to any questions of law decided by the trial court, but will defer to any factual findings made by that court if there is any evidence to sustain them. Nevertheless, if the trial court makes a finding of fact which is unsupported by the record, that finding cannot be upheld, and any judgment based upon such a finding must be reversed.

Denapoli v. Owen, 341 Ga. App. 517, 518 (801 SE2d 314) (2017) (citation and

punctuation omitted). So construed, the record shows that Petrov Tchotrov is the

owner and sole employee of SPN Trans, LLC (“SPN”). As part of its business

operations, SPN owns and operates a 2003 Freightliner tractor (the “truck”) and

attached trailer, which it leased to motor carriers in order to haul cargo loads.

On March 16, 2016, SPN and FBM Express, Inc. (“FBM”) entered into a

twelve-month lease, creating a carrier-independent contractor relationship wherein

2 SPN served as the independent contractor hauling loads for FBM, the carrier. The

lease contained an automatic one-year renewal provision, unless either party gave

written notice of intent not to renew at least 30 days before its expiration. Section V

of the lease, titled “Independent Contractor Warranty and Representation,” included

the following provision:

[SPN] warrants and represents that it is the owner of every unit of leased equipment and that [FBM] shall have possession of the equipment during the term of this [l]ease. [SPN] further warrants that every such unit of leased equipment shall be in safe mechanical and operating condition, free of defects, properly licensed[,] and in full compliance with the Motor Carrier Safety Regulations of the U. S. Department of Transportation (DOT) and all other applicable laws, regulations[,] and ordinances of Federal, State or Municipal authorities having jurisdiction [as] of the date it is delivered to [FBM] and shall be maintained as such throughout the term of this [l]ease.”

The lease required FBM to secure insurance coverage for any claims for when

the truck was being operated for business purposes on behalf of FBM, which was

done through a policy issued by Spirit Commercial Auto RRG (“Spirit”). The lease

further required SPN to obtain insurance for non-trucking liability that would cover

SPN and Tchotrov when the truck was not being used for FBM business. SPN

secured this required coverage by purchasing a commercial non-trucking liability

3 insurance policy with ASIC (the “Policy”), which contained a $1,000,000 limit for

any one accident or loss. The Policy’s Certificate of Insurance contained the

following exclusions from coverage, including when the truck: “[i]s being operated,

maintained or used to carry property in any business or en route for such purpose”;

“[i]s under [FBM] direction, control[,] or dispatch”; or “[i]s not under ‘permanent

lease’ with [FBM].”

As relevant here, on December 23, 2016, Evan Parrish was riding his

motorcycle when he was struck by Tchotrov, who was driving the truck without the

trailer. The truck left the scene, and Tchotrov initially denied knowledge of the

accident. However, he admitted that he drove the truck on the day of the accident to

have it repaired at an acquaintance’s house. The acquaintance, a mechanic, intended

to install a new air compressor in the truck at no charge. According to Tchotrov, FBM

later learned that the truck had been involved in an accident and then alerted Tchotrov

of this fact.

On January 5, 2017, ASIC learned of the December 23, 2016 accident

involving the truck. ASIC’s counsel sent SPN written notice on January 27, 2017,

4 indicating that ASIC was “investigating this matter subject to a full reservation of its

rights regarding coverage for this matter” under the Policy it had issued to SPN.

In mid-December, before the accident, Tchotrov had contacted the president

of FBM to discuss terminating the lease. According to Tchotrov, they agreed that

SPN would work for FBM through the end of 2016. FBM countered that Tchotrov

quit on December 22, 2016, and did not haul another load for FBM after that date.

On January 30, 2017, FBM sent Tchotrov a notice of the termination of the

lease with a Release of Equipment form, back-dating the termination to December 22,

2016, the day before the accident. In her deposition, FBM’s president testified that

the termination notice was sent on December 22, 2016. The form sent on January 30,

2017, suggests that it was signed by Tchotrov on December 22, 2016, but Tchotrov

insisted that he did not sign it until January 30, 2017, when he opened the email from

FBM.

ASIC filed a petition for a declaratory judgment in April of 2017, naming SPN,

Tchotrov, and Parrish as respondents.1 In its petition, ASIC sought a determination

1 ASIC later filed a motion for leave to amend its petition to add FBM as a party respondent, which the trial court granted. ASIC then filed a first amended petition for declaratory judgment, and completed service on FBM. After FBM failed to file a timely response, ASIC filed a motion for default judgment, which the trial court granted. FBM is not a party to the instant appeal.

5 that any potential claims raised in connection with the accident would not be

compensable under the terms of the Policy issued to SPN. Approximately a year later,

ASIC moved for summary judgment, arguing in pertinent part that neither SPN nor

Tchotrov was entitled to coverage as neither was an insured under the Policy because

a valid long term lease with a motor carrier was not in place when the accident

occurred, which was a policy coverage requirement.

The trial court denied ASIC’s motion for summary judgment, concluding that

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Bluebook (online)
American Southern Insurance Company v. Spn Trans, LLC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-southern-insurance-company-v-spn-trans-llc-gactapp-2021.