Brown v. Rock Ridge Insurance Company

CourtDistrict Court, W.D. Oklahoma
DecidedOctober 15, 2024
Docket5:24-cv-00771
StatusUnknown

This text of Brown v. Rock Ridge Insurance Company (Brown v. Rock Ridge Insurance Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Rock Ridge Insurance Company, (W.D. Okla. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

DOUG AND KATIE BROWN, ) ) Plaintiffs, ) ) v. ) Case No. 24-CV-771-D ) ROCK RIDGE INSURANCE COMPANY, ) ) Defendant. )

ORDER Before the Court is Plaintiffs’ Motion to Remand [Doc. No. 7]. The case arises out of a dispute between Plaintiffs Doug and Katie Brown and Defendant Rock Ridge Insurance Company, a foreign insurer. Plaintiffs allege that Defendant acted intentionally and maliciously in failing to perform a contract for homeowners insurance following a lightning strike that damaged Plaintiffs’ chimney. BACKGROUND On May 17, 2024, Plaintiffs filed their petition in the District Court of Oklahoma County [Doc. No. 1-1]. Pursuant to Okla. Stat. tit. 36, § 621(B) governing service of process on a foreign insurer, plaintiffs later mailed summons and a copy of the petition to the Oklahoma Insurance Department (“OID”) [Doc. No. 1-2, p. 1]. OID prepared a cover letter to Defendant at an address in Guaynabo, Puerto Rico [Doc. No. 7-1, p. 2], but instead of forwarding the cover letter, summons, and petition to the Puerto Rico address, OID forwarded the material to an address in Dallas, Texas [Doc. No. 7-1, p. 8]. In its brief, Defendant states that it had previously maintained an office at the Texas address. See Res. at 2. Delivery to the Texas address was attempted and failed. See Doc. No. 7-1, p. 8.

To avoid an unnecessary default, Plaintiffs’ counsel later reached out to OID and was informed that OID had two addresses on file for Defendant, one in Texas and the other in Puerto Rico. See Doc. No. 7-2, p. 1.1 Plaintiffs’ counsel requested OID make a second attempt at forwarding process by mailing the summons and petition to both addresses. Id. On July 9, 2024, OID forwarded the summons and petition to Defendant at its Puerto Rico address. See Doc. No. 7-3, pp. 1, 2. On July 29, 2024, Defendant removed the case to

this Court [Doc. No. 7-1]. In their Motion to Remand, Plaintiffs argue Defendant’s Notice of Removal is untimely because the 30-day removal deadline should begin to run from either the day OID received service—May 23, 2024—or the day OID forwarded service to the Texas address—June 6, 2024. For the reasons that follow, the Court disagrees.

STANDARD OF DECISION 28 U.S.C. § 1446(b)(1) requires that any notice of removal be filed “within thirty days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based.” State law, in turn, governs service. Murphy Bros., Inc. v. Michetti Pipe Stringing, Inc., 526

1 The parties’ briefs contest this fact. Defendant argues Plaintiffs’ counsel’s sworn affidavit, in which Plaintiff’s counsel recounts OID’s communications, is hearsay. The Court, however, is not relying on the affidavit but is instead making a reasonable inference about OID’s communication based on the course of events and an email attached to the Motion to Remand [Doc. No. 7-3, p. 1] in which an OID Legal Assistant stated OID had two addresses on file for Defendant. U.S. 344, 351 (1999). In Oklahoma, Okla. Stat. tit. 36, § 621(B) requires plaintiffs suing foreign insurers

to serve process “upon the Insurance Commissioner [or OID].” OID must then “promptly forward a copy thereof by mail with return receipt requested to the person last so designated by the insurer to receive the same.” Okla. Stat. tit. 36, § 622(A). Service is considered complete when OID forwards process. See 36 Okla. Stat. tit. 36, § 622(B). Removal statutes are strictly construed, and all doubts are to be resolved against removal. Fajen v. Found. Reserve Inc. Co., Inc., 683 F.2d 331, 333 (10th Cir. 1982) (citing

Shamrock Oil & Gas Corp. v. Sheets, 313 U.S. 100, 108-09 (1941)). DISCUSSION Plaintiffs argue the removal period under 28 U.S.C. § 1446(b) begins on the day service is complete under Oklahoma law. According to Plaintiffs, because Okla. Stat. tit. 36, § 622(B) institutes a mailbox rule for service on foreign insurers, and because the

record does not provide proof regarding who is to blame for OID forwarding service to the Texas address, all doubts should be resolved against removal and the deadline should begin to run, at the latest, on the date OID forwarded service to the Dallas address. Plaintiffs’ interpretation of § 1446(b) is imprecise. As the Supreme Court explained in Murphy Bros., 526 U.S. at 351, § 1446(b) was designed to “ensure that the defendant

would have access to the complaint before commencement of the removal period.” Id. Although Murphy Bros. addressed timeliness in the context of state statutes allowing for differing dates between when a defendant receives the complaint and the completion of formal service of the summons, the underlying justification applies equally here. Relying partially on Murphy Bros., Judge Eagan in Denny v. Illinois Nat. Ins. Co., No. 10-CV-0676-CVE-TLW, 2010 WL 5141656 (N.D. Okla. Dec. 13, 2010) analyzed the

interplay between § 1446 and Oklahoma law. Judge Eagan noted that “[f]ew states have a statutory agent mailbox rule similar to [Okla. Stat. tit. 36, § 622].” Id. at *4. Although the case law from those states was somewhat conflicted, “[t]he weight of the case law suggests that it is actual receipt by the defendant that controls for purposes of § 1446(b).” Id. at *5 (citing Freedom Steel, Inc. v. Senn Freight Lines, Inc., No. 1:09-CV-2750, 2010 WL 395228, at * 4 (N.D. Ohio, Jan. 26, 2010); Tucci v. Hartford Fin. Servs. Group, Inc., 600

F. Supp. 2d 630, 635 (D.N.J. Feb. 25, 2009)). Moreover, any contrary decision would “subject defendants to varying periods of removal based on the length of time it [takes] for documents to travel from [OID] to the party being served.” Id. at *5. Section 1446 was meant to counteract such variations by imposing a policy whereby “federal goals of notice and consistency are not sacrificed to state rules of procedure.” Id.

Rocky Branch Marina, L.L.C. v. Northern Assur. Co. of America, No. 09-CV-15- GKF-TLW, 2009 WL 997016 (N.D. Okla. Apr. 14, 2009) applies the same rationale. There, Judge Frizzell stated “[t]he general rule is that the thirty day clock for seeking removal does not begin to run when a statutory agent…is served.” Id. at *1. Judge Frizzell went on to quote the prevailing secondary literature on the topic at the time:

Realistically speaking, of course, these kinds of statutory agents are not true agents but are merely a medium for transmitting the relevant papers. Accordingly, it now appears to be settled law that the time for seeking removal begins to run only when the defendant or someone who is serving as the defendant’s agent in fact receives the process.

Id. (quoting 14C Charles Alan Wright, Arthur R. Miller, & Edward H Cooper, Federal Practice and Procedure: Jurisdiction § 3732 (3d ed.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Shamrock Oil & Gas Corp. v. Sheets
313 U.S. 100 (Supreme Court, 1941)
Tucci v. THE HARTFORD FINANCIAL SERVICES GROUP, INC.
600 F. Supp. 2d 630 (D. New Jersey, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
Brown v. Rock Ridge Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-rock-ridge-insurance-company-okwd-2024.