Benham v. First American Home Buyers Protection CA1/2

CourtCalifornia Court of Appeal
DecidedAugust 31, 2015
DocketA141034
StatusUnpublished

This text of Benham v. First American Home Buyers Protection CA1/2 (Benham v. First American Home Buyers Protection CA1/2) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benham v. First American Home Buyers Protection CA1/2, (Cal. Ct. App. 2015).

Opinion

Filed 8/31/15 Benham v. First American Home Buyers Protection CA1/2

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIRST APPELLATE DISTRICT DIVISION TWO

ALICE J. BENHAM, Plaintiff and Appellant, A141034 v. FIRST AMERICAN HOME BUYERS PROTECTION CORPORATION, (Contra Costa County Super. Ct. No. MSC1102389) Defendant and Respondent.

Alice J. Benham had a home warranty plan with First American Home Buyers Protection Corporation (First American). Benham’s furnace, which was covered by the plan, failed. She rejected the contractor selected by First American and hired her own contractor to replace her furnace. She filed a lawsuit against First American when it refused to reimburse her for the total amount she paid to replace the furnace. Subsequently, First American paid Benham the sum she had demanded, and Benham filed a first amended complaint against First American for breach of contract, breach of the covenant of good faith and fair dealing, and violation of the unfair competition law (UCL; Bus. & Prof. Code, § 17200 et seq.). First American moved for summary judgment, which the trial court granted. Benham appeals and contends, among other things, that the home protection plans are insurance, First American violated various regulations, and she suffered emotional distress damages. We decline to decide whether home protection plans are insurance

1 because such a determination is not necessary to our holding. Benham cannot show any damages on her breach of contract claim. The evidence shows as a matter of law that First American acted reasonably when complying with the terms of the contract, defeating Benham’s breach of the covenant of good faith and fair dealing claim. Finally, Benham suffered no economic injury and has no standing to bring a UCL claim. Accordingly, we affirm. BACKGROUND Benham purchased a home in the City of Richmond in 2010. Her real estate broker purchased for her benefit a home warranty plan with First American (First American’s home warranty plan), with an effective date of August 6, 2010. Such plans typically cover the major systems and appliances in a customer’s home. Benham acknowledged receiving this plan, but stated she did not read it when she received it. First American’s letter with the First American home warranty plan advised her to review it. First American’s home warranty plan provided that it “covers only the items mentioned as covered and excludes all other.” It stated that First American “will not reimburse you for services performed without approval.” With certain exclusions, First American’s home warranty plan covered heating.1 A provision in First American’s home warranty plan under the heading of “Limits of Liability” stated: “The Company will not be responsible for any corrections, repairs, replacements, upgrades, inspections or other additional costs to comply with federal, state or local laws, utility regulations, zoning or building codes. . . . The Company will not be responsible for alterations or modifications made necessary by existing equipment or

1 Under coverage for heating, the home warranty plan specified radiators; heating elements; vent blower assembly; baseboard convectors; gas, electrical, oil furnaces; switches, wiring and relays; gas valve; heat pump refrigerant recharging; motors; printed circuit boards; burners; hydronic circulating pumps; heat exchangers; heat pump; thermostats and thermostat sub-base.

2 installing different equipment except where noted in the Central Air Conditioning (Ducted) section of this contract. . . .” One paragraph in First American’s home warranty plan under the heading of “Customer Service” read: “Homeowner and Company may agree on payment of cash in lieu of repair or replacement. Payment will be made based on Company’s negotiated rates with its suppliers, which may be less than retail.” On October 18, 2010, the furnace in Benham’s home failed. She called Atlas Heating & Air Conditioning (Atlas), and an Atlas technician came to her home the following day. After meeting with Atlas, Benham called First American and reported that her furnace was not functioning. First American set up a work order for California Express Enterprises to inspect the furnace on October 20, 2010. The technician arrived at 10:30 a.m., on October 20, but Benham was not there. Benham requested a new contractor, and First American sent SA Heating & Air Conditioning (SA Heating) to her home on October 21, 2010. SA Heating inspected the furnace and reported several problems, including a cracked heat exchanger, a carbon monoxide leak, and an incorrect thermostat. SA Heating recommended replacement of the furnace and First American agreed to replace it. SA stated that a number of modifications would be required to install a replacement furnace. On October 22, 2010, First American placed a purchase work order with Goodman Distribution for a replacement furnace at 90 percent efficiency for the pre-tax price of $472.00. First American had a contract with SA Heating to provide service to its customers for a flat fee of $155.00. On October 22, 2010, First American sent Benham a letter stating that it had authorized SA Heating to replace the heater. The letter stated: “The price of the heater is $472.00[,] the tax is $46.02, and the labor rate is $155.00 to install. We do deduct the time into the job which is $55 and that totals your cash out to $618.00.” It specified that Benham would have to pay a total of $1,200 for costs not covered in the home warranty plan, which included, among other things, electrical and gas modifications and haul away and thermostat costs.

3 Benham wrote First American asking it to explain the non-covered costs, and First American responded that her home protection plan excluded the costs for alterations or modifications necessary to install different equipment or to correct prior improper installations. First American advised that she could receive $618.02 in lieu of the furnace replacement. Benham disputed these non-covered costs. On October 26, 2010, Benham sent an e-mail to First American telling it to send a copy of all future correspondence to her attorney, Robert F. Campbell. On November 9, 2010, Benham received an estimate from SA Heating to install a 95 percent efficiency brand furnace for the price of $2,750. Benham notified First American of this estimate. Benham received a proposal from Atlas to replace her furnace with a Goodman 92.1 percent efficiency furnace for $4,795.00. According to Benham, the market rate cost to replace her furnace was between $3,000 and $3,200. On November 15, 2010, First American sent a check for $618.02 to Benham. Above the signature line on the back of the check, it stated: “Endorsement of this check constitutes full release of First American Home Buyers Protection from making future repairs or replacement to your furnace.” Benham did not cash this check. Campbell wrote a letter dated February 3, 2011, on behalf of Benham to First American. The letter stated that Benham had obtained an estimate from a licensed heating and air-conditioning company indicating that the reasonable cost to install a comparable replacement furnace was $4,976.00. Deducting the uncovered costs of $1,200.00 from this estimate, First American, according to Campbell, owed Benham a minimum of an additional $3,157.98. On February 15, 2011, First American refused to pay the additional money requested. It stated that it “consider[ed] this claim closed.” On October 18, 2011, Benham sued for breach of contract and breach of the covenant of good faith and fear dealing.

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Benham v. First American Home Buyers Protection CA1/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/benham-v-first-american-home-buyers-protection-ca12-calctapp-2015.