Bettis v. National Union Fire, Unpublished Decision (4-26-2004)

2004 Ohio 2172
CourtOhio Court of Appeals
DecidedApril 26, 2004
DocketNo. 2003CA00251.
StatusUnpublished

This text of 2004 Ohio 2172 (Bettis v. National Union Fire, Unpublished Decision (4-26-2004)) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bettis v. National Union Fire, Unpublished Decision (4-26-2004), 2004 Ohio 2172 (Ohio Ct. App. 2004).

Opinions

OPINION
JUDGMENT ENTRY
{¶ 1} On December 27, 1996, appellee, Howard Bettis, was injured in an automobile accident caused by an uninsured motorist. At the time of the accident, appellee was employed by Republic Engineered Steels, insured under a commercial auto policy and a commercial general liability policy issued by appellant, National Union Fire Insurance Company.

{¶ 2} In January of 2001, appellee notified National Union he was seeking uninsured motorist benefits pursuant toScott-Pontzer v. Liberty Mutual Fire Insurance Co.,85 Ohio St.3d 660, 1999-Ohio-292.

{¶ 3} On June 22, 2001, appellee filed a complaint for declaratory judgment against National Union, among others, seeking benefits under the uninsured motorist provisions of the policies. Appellee requested binding arbitration, prejudgment interest, attorney fees and costs.

{¶ 4} On October 1, 2001, appellee filed a motion for default judgment based upon National Union's failure to answer. On October 11, 2001, counsel for National Union filed a notice of appearance as well as a motion seeking "additional time to file a response in this case." On October 15, 2001, National Union filed a motion for leave to file an answer and an answer.

{¶ 5} By judgment entry filed November 7, 2001, the trial court denied National Union's motion for leave to file an answer, and granted appellee's motion for default. Pursuant to a judgment entry filed December 21, 2001, the trial court ordered the matter to binding arbitration.

{¶ 6} By report filed October 3, 2003, the arbitrators found in favor of appellee in the amount of $625,000. By judgment entry filed June 9, 2003, the trial court setoff $100,000 previously received by appellee from another insurance company, and awarded appellee $525,000 plus prejudgment interest from December 18, 2003, and post-judgment interest.

{¶ 7} National Union filed an appeal and this matter is now before this court for consideration. Assignments of error are as follows:

I
{¶ 8} "The trial court erred in granting default judgment, when the record demonstrated that service was never properly perfected upon appellant, and the trial court's entry of November 7, 2001, and all subsequent entries based upon that entry must be reversed and vacated as void ab initio."

II
{¶ 9} "The trial court erred as a matter of law in awarding judgment by default in a declaratory judgment proceeding without a hearing and ordering the case to binding arbitration, particularly when the allegatons in the complaint were not on their face sufficient to support a finding of coverage, and without reviewing the pertinent policies of insurance, without making an independent legal determination as to the rights and obligations of the parties under the contracts, and without considering or permitting appellant to address issues regarding pro-rata contribution and priority of coverage."

III
{¶ 10} "The trial court erred in refusing to grant leave to appellant to file an answer to plaintiff's complaint and awarding default judgment against appellant without a hearing, when appellant presented evidence setting forth operative facts that would have justified relief, including evidence of meritorious coverage defenses, excusable neglect under 60(b)(1) and other 60(b)(5) factors, and timeliness of its motion."

I
{¶ 11} National Union claims the trial court erred in entering default judgment as service of the complaint was never perfected.

{¶ 12} The complaint names National Union as a defendant in care of "Robert A. Buffum of AIG Claims Services, Inc." with AIG's address, P.O. Box 3021, Blue Bell, Pennsylvania, 19422. The complaint was served by certified mail, return receipt requested, and service was perfected on June 28, 2001.

{¶ 13} National Union argues it is a separate corporation incorporated in Pennsylvania and having its principle place of business in New York City. AIG Claims Services, Inc. is a separate entity, incorporated in Delaware and also having its principle place of business in New York. The complaint was sent to the Blue Bell, Pennsylvania address.

{¶ 14} Mr. Buffum submitted an affidavit to the court in which he concedes he dealt with appellee's claim. Mr. Buffum alleges he handles claims for multiple insurance companies affiliated with AIG, and therefore acts as their agents, although he is not general or managing agent of these companies for purposes of service. Mr. Buffum states he fully intended to obtain information about the case and to defend. He also alleges he is not certain how or why counsel did not receive the complaint sooner.

{¶ 15} On October 1, 2001, appellee filed his motion for default judgment. National Union filed a notice of appearance on October 11, 2001, and on October 15, 2001, filed a motion for leave to file an answer and an answer. On November 7, 2001, the trial court denied the motion for leave to plead and entered default judgment against National Union. National Union did not file an appeal at this time. On December 21, 2001, the trial court ordered the parties to binding arbitration. After the arbitration panel returned its report and award, appellee moved the trial court to confirm the arbitration award and reduce it to judgment. The trial court noted the matters before the arbitration panel were proximate cause and damages.

{¶ 16} As an added problem, appellee did not have complete certified copies of the National Union insurance policies attached to his complaint. Instead, he attached an unauthenticated copy of a declaration page. With his motion for default judgment, appellee attached unauthenticated declaration pages and an unauthenticated document entitled "Ohio Uninsured Motorist Coverage-Property Damage" which bore the number of one of the policies National Union had issued. National Union argues the policies were never filed with the trial court prior to the default judgment and hence there was no documentation before the trial court supporting a finding of coverage in favor of appellee as against National Union.

{¶ 17} In its November 7, 2001 judgment entry, the trial court found National Union had notice of the claim prior to the filing of the complaint. National Union provided Mr. Buffum with the notice and authorized him to act as their representative in dealing with the claim. The trial court reviewed a letter dated February 28, 2001 from Mr. Buffum to appellee's counsel. The letter is three pages long, and asserts AIG Claims Services, Inc. is an authorized representative of National Union Fire Insurance Company of Pittsburgh, Pennsylvania, and refers thereafter in the letter to National Union as "The Company." The letter requests information about the motor vehicle accident and about appellee's injuries. The last section of the letter is "The Insurance Company's Position." The letter specifically states that by accepting notice of the claim and proceeding with its investigation, the company, i.e., National Union, is reserving its rights based upon the terms, conditions, exclusions, and definitions found within its policies.

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Bluebook (online)
2004 Ohio 2172, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bettis-v-national-union-fire-unpublished-decision-4-26-2004-ohioctapp-2004.