BITCO General Insurance Corporation v. Union Ridge Ranch LLC

CourtDistrict Court, W.D. Washington
DecidedAugust 22, 2024
Docket3:22-cv-05624
StatusUnknown

This text of BITCO General Insurance Corporation v. Union Ridge Ranch LLC (BITCO General Insurance Corporation v. Union Ridge Ranch LLC) 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
BITCO General Insurance Corporation v. Union Ridge Ranch LLC, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 BITCO GENERAL INSURANCE CASE NO. C22-05624 BHS 8 CORPORATION, ORDER 9 Plaintiff, v. 10 UNION RIDGE RANCH, LLC and 11 INLAND COMPANY, 12 Defendants. 13

This matter is before the Court on defendant Inland Company’s motion for partial 14 summary judgment, Dkt. 24, and Plaintiff BITCO General Insurance Corporation’s 15 motion for partial summary judgment, Dkt. 35. 16 The central issue before the Court is whether Inland’s BITCO’s insurance 17 policies1 cover damage that Inland caused to Union Ridge Ranch (URR). Inland 18 improperly constructed retaining walls on URR’s property, one of which failed. The 19 20

21 1 Inland had a BITCO Comprehensive General Liability (CGL) policy and an umbrella policy. Both had the same coverages and exclusions, and they will be referenced in the singular 22 for clarity and ease of reference. 1 policy includes an “Impaired Property” exclusion which excludes from coverage property 2 that is “less useful” because it incorporates Inland’s defective work. Dkt. 1-1 at 55. An

3 exception to this exclusion applies if Inland can prove the “loss of use of other property 4 arising out of sudden and accidental physical injury” to Inland’s work or product after it 5 has been put to its intended use. Dkt. 1-1 at 63. Inland concedes that not only the failed 6 retaining wall but “the complete parcel” of land falls within the definition of impaired 7 property. Dkt. 24 at 11. But it argues that the failure of the retaining wall satisfies the 8 sudden and accidental injury exception to the impaired property exclusion. Id. at 12–13.

9 The Court disagrees. For the reasons explained below, it concludes that the exception 10 does not apply and that the impaired property exclusion bars coverage here. 11 I. BACKGROUND 12 URR owned real property in Ridgefield, Washington which it planned to develop 13 and sell to a buyer to construct homes (the Project). Dkt. 1-2 at 3–4. It hired Inland in the

14 summer of 2018 to perform infrastructure work on its land including constructing 15 retaining walls as well as storm, sewer, water, sitework, earthwork, rock, paving and 16 concrete work. Dkt. 26-11 at 3. 17 URR made its first attempt to sell the Project in October of 2018. Dkt. 1-2 at 23. 18 As part of due diligence, the purchaser commissioned a geotechnical analysis of the

19 project. Id. The report “identified numerous defects and deficiencies with [Inland’s] 20 work, including but not limited to, the retaining walls were not built correctly and in 21 accordance with the approved design plans, there was a substantial risk of future wall 22 failures and displacements, particularly during the wet winter season, and other defects.” 1 Id. The buyer terminated its agreement to purchase the project in November 2018 due to 2 the defects identified in Inland’s work by the report. Id.

3 URR met with Inland in November 2018 to point out the defects in Inland’s work, 4 discuss the buyer’s cancelation, and address cost overruns and funding problems. Dkt. 1- 5 2 at 23. In addition to the retaining wall issues uncovered by the geotechnical report, 6 URR concluded Inland had also failed to provide adequate manpower for tasks, to adhere 7 to timelines, and to provide accurate invoices and records to URR. Id. Inland agreed to 8 work with URR on a reduced final contract price. Id.

9 On January 17, 2019, URR and Inland discovered that one of the retaining walls 10 (Wall 4) had failed. Dkt. 1-2 at 24. They were on the site to discuss the Project, and the 11 issues with the retaining walls, when they allegedly2 discovered that the central portion of 12 Wall 4 was bulging with water pooling at its top. Id.; Dkt. 24 at 6. At that time, only the 13 central portion of the wall was constructed, the “wings” were not yet in place. Dkt. 24 at

14 6 n.2. By February 2019, a Project engineer opined that “the entire wall No. 4 has been 15 compromised.” Dkt. 39-4 at 2. 16 The failure of Wall 4 necessitated a redesign and rebuild. The rebuilding of the 17 wall did not begin until several months after January 2019. Dkt. 25 at 8, 10. URR 18 commissioned a report (J2 report) to analyze what went wrong with the project with

2 Inland cites to “Vial Dec, Ex 1, page 4 (J2 Report)” to support its assertion that the wall 20 was seen “bulging” with water “pooling” on top. It does not specify which Vial declaration. In any event, page 4 of the J2 does not include any reference to bulging or pooling with Wall 4. A 21 word search in the J2 report for “bulge” or “pool” came up with zero results. Inland made no correction when BITCO pointed this out. Dkt. 31 at 11 n.5. Consequently, the Court does not 22 assume the truth of those details. 1 regards to “standard of care for design professionals, construction and general design 2 errors, design and construction delays, and contract administration standards of care.”

3 Dkt. 25 at 3. It concluded that “the improper installation of this wall ultimately led to 4 prospective buyers losing confidence in the project, extending the construction duration 5 too far and ultimately led to the developer [Union Ridge] losing the property [.].” Id. at 8. 6 In February 2019, Soil & Water Technologies, Inc. (SWT), the geotechnical consultant 7 hired by the Project engineer, issued a report that determined that all the retaining walls 8 were still defective. Dkt. 1-2 at 24.

9 As winter 2019 wore on, tensions rose between Inland and URR. Inland demanded 10 payment for its work and money for the necessary adjustments and URR refused to pay 11 for future work or work that it deemed improper and demanded an economical solution 12 for the damage already done. Dkt. 1-2 at 24–25. In March 2019, Inland filed four Claims 13 of Lien against the project. Dkt. 1-1 at 25.

14 On April 2, 2019, Inland sued URR in Clark County Superior Court, asserting 15 breach of contract and quantum meruit claims and seeking to foreclose on its lien. Dkt. 16 37 at 3–17. 17 A few weeks later in April 2019, URR found a second potential purchaser who 18 agreed to purchase the Project contingent on due diligence. Dkt. 1-2 at 26. Inland refused

19 to withdraw its liens against the Project which would have allowed the Clark County 20 Recorder’s office to officially record the Project for sale. Id. It also had not yet completed 21 the retaining walls by May 2019. Id. This second purchaser did not buy the Project. Id. 22 1 Between April and July 2019, URR continued to demand that Inland complete the 2 Project and repair the retaining walls and related elements. Dkt. 1-2 at 26–27. Inland

3 refused until May and June of 2019 when it attempted to rebuild and repair all of the 4 retaining walls. Id. at 26. 5 In June 2019, URR found a third potential buyer. That buyer commissioned 6 geotechnical testing of the Project which confirmed that the walls were still not 7 constructed correctly and that they would fail in the future. Dkt. 1-2 at 27. URR 8 ultimately sold the project, but for a reduced price in order to account for re-building and

9 repairing all of the retaining walls. Id. 10 A. URR’s Counterclaims against Inland 11 In its July 2019 answer to Inland’s suit, URR asserted breach of contract and 12 negligence counterclaims. It claimed Inland’s poor work on not just the retaining walls 13 but in varied aspects of construction that had made it impossible to sell the project at a

14 profit and sought $2,007,085.10 in damages. Dkt. 1-2 at 20–34.

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Bluebook (online)
BITCO General Insurance Corporation v. Union Ridge Ranch LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bitco-general-insurance-corporation-v-union-ridge-ranch-llc-wawd-2024.