Anderson v. State Farm Fire & Casualty Company

CourtDistrict Court, W.D. Washington
DecidedJuly 31, 2024
Docket3:20-cv-05119
StatusUnknown

This text of Anderson v. State Farm Fire & Casualty Company (Anderson v. State Farm Fire & Casualty Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. State Farm Fire & Casualty Company, (W.D. Wash. 2024).

Opinion

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6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 DALE ANDERSON et al., CASE NO. 3:20-cv-05119-DGE 11 Plaintiff, ORDER ON MOTION FOR 12 v. STATUTORY DAMAGES, PREJUDGMENT INTEREST, 13 STATE FARM FIRE & CASUALTY REASONABLE ATTORNEY FEES, COMPANY, AND NONTAXABLE COSTS 14 (DKT. NO. 106) Defendant. 15 16 I INTRODUCTION 17 Before the Court is Plaintiffs Dale and Leta Anderson’s Motion for Statutory Damages, 18 Prejudgment Interest, Reasonable Attorney Fees, and Nontaxable Costs. (Dkt. No. 106.) Upon 19 review of that motion, Defendant’s response (Dkt. No. 111), Plaintiffs’ reply (Dkt. No. 112), and 20 the remaining record, the Court GRANTS IN PART and DENIES IN PART the motion. 21 II BACKGROUND 22 The Court presumes familiarity with the facts of this case. (See Dkt. No. 56 at 1–3.) 23 After a trial on the merits, the jury found for Plaintiffs on all claims, finding State Farm acted in 24 ORDER ON MOTION FOR STATUTORY DAMAGES, PREJUDGMENT INTEREST, REASONABLE 1 bad faith, violated the Consumer Protection Act (“CPA”), and was negligent in breaching one or 2 more of the duties of insurance agents, proximately causing damage to the Andersons in the 3 amount of $1 million. (Dkt. No. 103.) On May 16, 2024, the Court entered judgment on the 4 verdict in the amount of $1 million (Dkt. No. 104), which the Andersons now move to amend to 5 include statutory treble damages and prejudgment interest, as well as for an award of reasonable

6 attorney fees and nontaxable litigation costs. (Dkt. No. 106 at 3.) 7 III DISCUSSION 8 A. Statutory damages under the CPA 9 Plaintiffs move for an award of treble damages in the amount of $25,000 under the CPA. 10 (Dkt. No. 106 at 3–4.) Plaintiffs argue under § 19.86.090 of the Washington Revised code, “the 11 Court may, in its discretion, increase the award of damages up to an amount not to exceed three 12 times the actual damages sustained” and “such increased damage may not exceed twenty-five 13 thousand dollars” when a defendant is found to have violated § 19.86.020. Rev. Code. Wash. 14 § 19.86.090.

15 Defendant argues treble damages must be sought from the jury. (Dkt. No. 111 at 8–9.) 16 In support of its argument, Defendant cites MKB Constructors v. Am. Zurich Ins. Co. 83 F. Supp. 17 3d 1078, 1082 (W.D. Wash. 2015) and Northwestern Mut. Life Ins. Co. v. Koch, 771 F. Supp. 2d 18 1253 (W.D. Wash. 2009). (Dkt. No. 111 at 8.) These cases are not applicable because they 19 discuss jury-awarded enhanced damages under the Insurance Fair Conduct Act pursuant 20 Washington Revised Code § 48.30.015(2) rather than court-awarded treble damages under the 21 CPA pursuant to § 19.86.020. MKB Constructors, 83 F. Supp. 3d at 1082; Northwestern Mut., 22 771 F. Supp. 2d at 1254. Defendant also argues treble damages are punitive damages, and thus 23 must be determined by the jury if requested by the plaintiff. (Dkt. No. 111 at 8.) This argument 24 1 is misplaced. Treble damages are not punitive damages; rather, they are statutory liquidated 2 damages. Segar v. Allstate Fire and Casualty Ins. Co., No. C21-1526JLR, 2022 WL 102035, at 3 *4 n.8 (W.D. Wash. Jan. 11, 2022). The statute clearly states “the Court may, in its discretion, 4 increase the award of damages” under the CPA; a jury is not required to award these statutory 5 damages. Rev. Code. Wash. § 19.86.090.

6 Treble damages are based upon the actual damages awarded in the underlying case. See 7 Gamble v. State Farm Mut. Auto. Ins. Co., No. C19-5956, 2022 WL 92985, at *7 (W.D. Wash. 8 Jan. 10, 2022). Defendant argues even if treble damages could be awarded by the Court on a 9 post-judgment motion, because the verdict form did not set forth the specific damages awarded 10 based on each of the three legal theories, there is no way to determine the “actual” damages for 11 the CPA claim or whether more than nominal damages were awarded under the CPA. (Dkt. No. 12 111 at 9.) Treble damages may only be based upon actual damages; because there is not an 13 established base number to treble, Defendant argues there is no way to determine a treble 14 damages award. (Id.)

15 In Gamble, the case Plaintiffs cited in their reply, the jury awarded discrete damages for 16 each violation of law: $50,000 for breach of contract, $50,000 for violating the Insurance Fair 17 Conduct Act, and $50,000 for violating the Consumer Protection Act, among other awards. 18 Gamble, No. C19-5956, Dkt. No. 135 (W.D. Wash. Nov. 3, 2021). Based on the $50,000 in 19 actual damages under the CPA, the Court awarded treble damages at the $25,000 maximum. See 20 Gamble, 2022 WL 92985, at *7. 21 Here, the verdict form simply asked the jury: “What is the amount of the Anderson[s’] 22 damages?” (Dkt. No. 103 at 3.) The jury did not partition the $1 million award by the bad faith, 23 CPA, or negligence claims. Because the Court has no amount of “actual damages” that can be 24 1 attributable to the CPA claim, the Court is without a base number to treble. See also St. Paul 2 Fire & Marine Ins. Co. v. Updegrave, 656 P.2d 1130, 1134 (1983) (finding no award of treble 3 damages where insured “did not prove that it suffered any monetary damages of a particular 4 sum”). Plaintiffs fail to identify, nor is this Court able to find, a case in which treble damages 5 were awarded on top of a generalized damages award not divided by claim. Because the

6 Andersons’ actual damages under the CPA are unknown, the Court cannot treble them under 7 § 19.86.090. 8 B. Prejudgment interest 9 Plaintiffs also request the jury’s award be amended to include prejudgment interest fees. 10 (Dkt. No. 106 at 4.) Prejudgment interest is available “(1) when an amount claimed is 11 ‘liquidated’ or (2) when the amount of an ‘unliquidated’ claim is for an amount due upon a 12 specific contract for the payment of money and the amount due is determinable by computation 13 with reference to a fixed standard contained in the contract, without reliance on opinion or 14 discretion.” Rekhter v. State, Dept. of Soc. and Health Servs., 323 P.3d 1036, 1047 (Wash.

15 2014). A claim is liquidated “where the evidence furnishes data which, if believed, makes it 16 possible to compute the amount with exactness, without reliance on opinion or discretion.” 17 Scoccolo Const., Inc. ex rel. Curb One, Inc. v. City of Renton, 145 P.3d 371, 377 (Wash. 2006). 18 A claim is unliquidated where “the exact amount of the sum to be allowed cannot be definitely 19 fixed from the facts proved, disputed or undisputed, but must in the last analysis depend upon the 20 opinion or discretion of the judge or jury as to whether a larger or a smaller amount should be 21 allowed.” Id. 22 In this case, the amount claimed is liquidated. The jury’s award of $1,000,000 is the 23 amount Plaintiffs paid when they settled the underlying litigation without coverage by the policy 24 1 State Farm negligently failed to procure. The amount is fixed from the facts proven and the jury 2 did not exercise discretion in determining what the Andersons’ award should be. Indeed, “it now 3 appears to be nearly axiomatic that ‘settlements in underlying civil actions are liquidated 4 amounts’” and “a settlement made in an underlying civil action represents a liquidated amount 5 and an award of prejudgment interest is appropriate.” Reynolds Metals Co. v. Alcan, Inc., No.

6 C04-0175RJB, 2006 WL 1806186, at *4 (W.D. Wash. June 29, 2006); see also King County v. 7 Puget Sound Power & Light Co., 852 P.2d 313 (Wash. App. 1993) (citing Valloric v.

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Anderson v. State Farm Fire & Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-state-farm-fire-casualty-company-wawd-2024.