Cameron v. Country Mutual Insurance Company

CourtDistrict Court, E.D. Washington
DecidedOctober 23, 2024
Docket1:24-cv-03075
StatusUnknown

This text of Cameron v. Country Mutual Insurance Company (Cameron v. Country Mutual Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cameron v. Country Mutual Insurance Company, (E.D. Wash. 2024).

Opinion

1 FILED IN THE 2 U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON Oct 23, 2024 3 SEAN F. MCAVOY, CLERK 4 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 GEORGE CAMERON AND JANIN No. 1:24-CV-03075-MKD CAMERON, Country Mutual Insurance 8 Company claimants, and all others ORDER DISMISSING CASE FOR similarly situated throughout LACK OF SUBJECT MATTER 9 Washington State and the United States JURISDICTION of America, 10 Plaintiffs, 11 v. 12 COUNTRY MUTUAL INSURANCE 13 COMPANY, an insurance company; COUNTRY FINANCIAL, an insurance 14 conglomerate; COUNTRY CASUALTY INSURANCE COMPANY, an 15 insurance company; COUNTRY PREFERRED INSURANCE 16 COMPANY, an insurance company; COUNTRY INVESTOR LIFE 17 ASSURANCE COMPANY, an insurance company; and COUNTRY 18 LIFE INSURANCE COMPANY, an insurance company, 19 Defendants. 20 1 Before the Court are the following three motions: (1) Defendant Country 2 Mutual Insurance’s (“CMIC”) Motion to Dismiss and to Strike Plaintiffs’ Class

3 Allegations, ECF No. 21; (2) the other appearing Defendants’ (the “Country 4 Affiliates”)1 Joint Motion to Dismiss, ECF No. 23; and (3) Plaintiffs’ Motion to 5 Certify a Class, ECF No. 25. For the reasons explained below, the Court dismisses

6 the case for lack of subject matter jurisdiction. 7 BACKGROUND 8 The Complaint asserts claims for unfair or deceptive practices in violation of 9 the Washington Consumer Protection Act (CPA). ECF No. 1 at 7-10 ¶¶ 4.1-6.4.

10 Plaintiffs named CMIC, the Country Affiliates, and Country Financial as 11 Defendants. ECF No. 1 at 2-3 ¶¶ 1.5-1.10. 12 All claims stem from Plaintiffs’ “Agriplus” farm insurance policy issued by

13 CMIC. See ECF No. 1 at 3 ¶¶ 2.1-2.3; ECF No. 9-1. Plaintiffs contend that this 14 policy was also issued by Country Financial, see ECF No. 1 at 3 ¶ 2.1, 4 ¶ 2.4, 5 ¶¶ 15 2.14-2.22. In brief, Plaintiffs allege that CMIC and Country Financial violated 16 various provisions of the Washington Administrative Code in handling Plaintiffs’

18 1 The Country Affiliates include (1) Country Casualty Insurance Company, 19 (2) Country Preferred Insurance Company, (3) Country Investor Life Assurance 20 Company, and (4) Country Life Insurance Company. See ECF No. 23 at 5. 1 insurance claim for losses sustained in a January 2022 fire. See id. at 3-5 ¶¶ 2.3- 2 2.22. Plaintiffs indicated that they intend to bring a class action alleging a

3 violation of the Washington CPA on behalf of “all individuals throughout 4 Washington State and throughout the United States who have submitted a claim to 5 [CMIC] or Country Financial which was partially or totally denied.” Id. at 6-7 ¶¶

6 3.1-3.11 (emphasis added). Plaintiffs also bring claims against the Country 7 Affiliates, ostensibly on the basis that they are “wholly owned and controlled by 8 Country Financial and implement[] the same settlement practices as [CMIC].” See 9 id. at 3 ¶¶ 1.7-1.10, 7 ¶ 4.1 (“Defendants have violated RCW 19.86.020 . . . .”), 10

10 ¶ 6.4 (“Defendants should be enjoined to adopt claim settlement practices which 11 comply with the CPA . . . .”). 12 Plaintiffs filed a proof of service for CMIC and waivers of service from the

13 Country Affiliates. ECF Nos. 5, 6. To date, Plaintiffs have not served Country 14 Financial, and Country Financial has not otherwise appeared in this matter. See 15 ECF No. 42 at 4-5. The parties dispute whether Country Financial is a legal entity 16 that may be subject to suit; Plaintiffs contend that their failure to serve this entity in

17 the time required by Fed. R. Civ. P. 4(m) should be excused until this dispute is 18 resolved. See id. 19 CMIC moved to dismiss the Complaint pursuant to Fed. R. Civ. P. 12(b)(6)

20 and to strike the class allegations. ECF No. 21. The Country Affiliates moved to 1 dismiss the Complaint for lack of Article III standing and incorporate the 2 arguments in CMIC’s motion. ECF No. 23. Shortly thereafter, Plaintiffs moved to

3 certify a class. ECF No. 25. 4 Although Defendants had not raised the issue, the Court observed that 5 Plaintiffs had not alleged subject matter jurisdiction in the Complaint. See ECF

6 No. 1; ECF No. 38 at 2. In advance of the motion hearing, the Court directed 7 Plaintiffs to file a brief containing the legal and factual grounds for federal subject 8 matter jurisdiction and ordered Plaintiffs to show cause why Defendant Country 9 Financial had not been served in accordance with Fed. R. Civ. P. 4(m). ECF

10 No. 38. Plaintiffs submitted a brief regarding the service issue, see ECF No. 39, 11 but did not file any briefing on subject matter jurisdiction before the hearing. 12 At the hearing, Plaintiffs’ counsel acknowledged that he had overlooked the

13 Court’s order requesting further briefing on subject matter jurisdiction and that the 14 Complaint did not contain a jurisdictional statement. Plaintiffs’ counsel stated that 15 Plaintiffs intended to invoke diversity jurisdiction under the Class Action Fairness 16 Act (CAFA) and conceded that Plaintiffs could not meet the amount-in-

17 controversy requirement for ordinary diversity jurisdiction under 28 U.S.C. 18 § 1332(a). After the hearing, Plaintiffs’ counsel filed a supplemental brief 19 memorializing these arguments and proposing language for an amended complaint

20 to correct the lack of a jurisdictional statement. ECF No. 42. 1 LEGAL STANDARD 2 “Federal courts are courts of limited jurisdiction and, as such, cannot

3 exercise jurisdiction without constitutional and statutory authorization.” Kokkonen 4 v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). “It is the duty of 5 federal courts to assure themselves that their jurisdiction is not being exceeded.”

6 HayDay Farms, Inc. v. FeeDx Holdings, Inc., 55 F.4th 1232, 1238 (9th Cir. 2022) 7 (quoting In re Ryther, 799 F.2d 1412, 1414 (9th Cir. 1986)) (quotation marks 8 omitted). Therefore, “a court may raise the question of subject matter jurisdiction, 9 sua sponte, at any time during the pendency of the action . . . .” Nevada v. Bank of

10 Am. Corp., 672 F.3d 661, 673 (9th Cir. 2012) (quoting Snell v. Cleveland, Inc., 316 11 F.3d 822, 826 (9th Cir. 2002)) (quotation marks omitted). 12 DISCUSSION

13 In each complaint, a plaintiff must provide “a short and plain statement of 14 the grounds for the court’s jurisdiction, unless the court already has jurisdiction 15 and the claim needs no new jurisdictional support.” Fed. R. Civ. P. 8(a)(2). The 16 Complaint clearly lacks any statement of the grounds for federal subject matter

17 jurisdiction and, therefore, cannot proceed in its current form. The remaining 18 question is whether Plaintiffs should be given an opportunity to amend. 19 A court may allow the plaintiff to amend their pleadings to cure

20 jurisdictional deficiencies at any stage of the proceedings. 28 U.S.C. § 1653; see 1 also NewGen, LLC v.

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Bluebook (online)
Cameron v. Country Mutual Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cameron-v-country-mutual-insurance-company-waed-2024.