Bridgeman v. Cruz

21 Pa. D. & C.5th 236
CourtPennsylvania Court of Common Pleas, Monroe County
DecidedJanuary 7, 2011
Docketno. 7030 CIVIL 2010
StatusPublished

This text of 21 Pa. D. & C.5th 236 (Bridgeman v. Cruz) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Monroe County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bridgeman v. Cruz, 21 Pa. D. & C.5th 236 (Pa. Super. Ct. 2011).

Opinion

MILLER, J.,

The current dispute stems from an automobile accident which occurred on August 8, 2008. On that date, plaintiff Alexandra Bridgeman (“plaintiff’) and defendant Danny Cruz (“Cruz”) were traveling in opposite directions [238]*238on Coolbaugh Drive in Middle Smithfield Township, Monroe County, Pennsylvania. Cruz was driving a car owned by defendant Mary Rodriguez (“Rodriguez”). Cruz struck the rear of the car in front of him, driven by Sylvette Hartroth, as Ms. Hartroth attempted to turn left into Pocono Heights. The impact sent Ms. Hartroth’s car into the oncoming lane where it struck plaintiff’s vehicle.

Plaintiff filed a complaint on July 27, 2010, which asserted a claim in negligence against Cruz and claims for vicarious liability and negligent entrustment against Rodriguez. Plaintiff also asserted a claim against defendant Nationwide Insurance Company (“Nationwide”), plaintiff’s insurer, for recovery above and beyond the alleged tortfeasor-defendants’ applicable policy limits, under plaintiff’s insurance contract which provided for uninsured (“UM”) and underinsured motorist (“UIM”) coverage pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law (“MVFRL”), 75 Pa. C.S. § 1701, et seq.

On September 20,2010, Nationwide filed a cross-claim which alleged that defendants Cruz and Rodriguez were liable to Nationwide for contribution or indemnification of any amounts that Nationwide had to pay to plaintiff under the terms of plaintiff’s uninsured and underinsured motorist coverage. Nationwide claimed, essentially, that any amount it was required to pay to plaintiff under the policy was due to the actions of Cruz and Rodriguez, the alleged primary tortfeasors. Defendants Cruz and Rodriguez filed preliminary objections to Nationwide’s cross-claim on October 7,2010 and argued that Nationwide had no right to contribution or indemnification because they [239]*239were brought into the case on an uninsured or underinsured motorist theory of recovery.

We held oral arguments on December 6, 2010 and are now ready to rule on this matter. For the following reasons, we sustain defendants’ preliminary objections and strike Nationwide’s cross-claim, as Nationwide’s claim for contribution or indemnification is not yet ripe for judicial review.

The legal concept of justiciability encompasses the related questions of who may properly bring a claim before a court, and when that claim may properly be brought. A litigant must satisfy three threshold requirements before a claim can be considered justiciable: (1) the litigant must have standing to bring the action; (2) the claim must not be moot; and (3) the claim must be ripe for judicial review. See Rendell v. Pennsylvania State Ethics Comm’n, 603 Pa. 292, 983 A.2d 708 (2009).

To be ripe for judicial review, “an actual case or controversy must exist at every stage of the judicial process.” Richards v. Trimbur, 543 A.2d 116, 119 (Pa. Super. 1988). The rationale for the ripeness doctrine is to prevent premature adjudications. Rouse & Associates-Ship Road Land LP v. Pennsylvania Environmental Quality Bd., 642 A.2d 642 (Pa. Cmwlth. 1994). To determine whether a claim is ripe for review, the court must consider two factors: (1) whether the issues are adequately developed for judicial review, and (2) what hardships, if any, the parties will suffer if review is delayed. Braksator v. Zoning Hearing Bd. of Northampton Twp., 641 A.2d 44 (Pa. Cmwlth. 1994). The court should analyze “whether the claim involves uncertain or contingent events that may not occur as antici[240]*240pated or at all,” and whether any actual hardship creates a ” "direct and immediate’ dilemma for the parties, such that the lack of pre-enforcement review will put the parties to costly choices.” Alaica v. Ridge, 784 A.2d 837, 843 (Pa. Cmwlth. 2001) (citing Philadelphia Fed’n of Teachers v. Ridge, 150 F.3d 319 (3d Cir. 1998)).

The Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S. § 1701, et seq., provides in relevant part that insurers must offer uninsured and underinsured motorists coverage to prospective automobile insurance purchasers. See 75 Pa. C.S. § 1731. The purpose of uninsured and underinsured motorist coverage is to pass the risk of loss to the insurer when a tortfeasor cannot fully compensate the insured for the insured’s injuries. Kmonk-Sullivan v. State Farm Mut. Auto. Ins. Co., 746 A.2d 1118 (Pa. Super. 1999).

“[ Underinsurance coverage is always secondary, or excess, coverage by its very nature; the insurer pays nothing unless and until the tortfeasor’s coverage is exhausted, and then only if damages exceed the tortfeasor’s insurance limits.” Allwein v. Donegal Mut. Ins. Co., 671 A.2d 744, 757 (Pa. Super. 1996). In other words, the insured must first recover from the primary tortfeasor and then look to the uninsured or underinsured motorist carrier for excess coverage. Id. Additionally, a claim for uninsured or under-insured motorist benefits is not ripe until all other coverage limits have been exhausted. Condio v. Erie Ins. Exch., 899 A.2d 1136, 1150 (Pa. Super. 2006).

After the insurer compensates the insured, the “insurer who paid a UIM claim acquires, by operation of law, the right to seek subrogation from any person that the in[241]*241sured could have pursued who should rightly have borne the loss.” Pusl v. Means, 982 A.2d 550 (Pa. Super. 2009). While no specific statutory provision governs insurer’s subrogation rights involving uninsured and underinsured motorist claims, common law rights of subrogation are available to insurers who pay underinsured benefits to their insureds. Johnson v. Beane, 541 Pa. 449, 664 A.2d 96 (1995). Furthermore, “the insured must be fully compensated, or ‘made whole,’ for injuries suffered before the right of subrogation on the part of the insurer arises.” Pusl, 982 A.2d at 557.

Plaintiff’s insurance contract with defendant Nationwide contains certain provisions that detail the proper procedures for recovery and subrogation under the contract. For example, the contract states:

Before recovery, [Nationwide] aid any injured party seeking protection under this coverage must agree on two points:
a) whether there is a legal right to recover damages from the owner or driver of an iminsured [or underinsured] motor vehicle; and if so,

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Related

Allwein v. Donegal Mutual Insurance
671 A.2d 744 (Superior Court of Pennsylvania, 1996)
Richards v. Trimbur
543 A.2d 116 (Supreme Court of Pennsylvania, 1988)
Johnson v. Beane
664 A.2d 96 (Supreme Court of Pennsylvania, 1995)
Pusl v. Means
982 A.2d 550 (Superior Court of Pennsylvania, 2009)
Insurance Adjustment Bureau, Inc. v. Allstate Insurance
905 A.2d 462 (Supreme Court of Pennsylvania, 2006)
Kmonk-Sullivan v. State Farm Mutual Automobile Insurance
746 A.2d 1118 (Superior Court of Pennsylvania, 1999)
Alaica v. Ridge
784 A.2d 837 (Commonwealth Court of Pennsylvania, 2001)
Rendell v. Pennsylvania State Ethics Commission
983 A.2d 708 (Supreme Court of Pennsylvania, 2009)
MIIX Insurance Co. v. Epstein
937 A.2d 469 (Superior Court of Pennsylvania, 2007)
Braksator v. Zoning Hearing Board
641 A.2d 44 (Commonwealth Court of Pennsylvania, 1994)
Condio v. Erie Insurance Exchange
899 A.2d 1136 (Superior Court of Pennsylvania, 2006)

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Bluebook (online)
21 Pa. D. & C.5th 236, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bridgeman-v-cruz-pactcomplmonroe-2011.