Capitol Specialty Insurance Corporation v. Amtrust International Under Writers Limited

CourtDistrict Court, S.D. California
DecidedOctober 31, 2019
Docket3:18-cv-00707
StatusUnknown

This text of Capitol Specialty Insurance Corporation v. Amtrust International Under Writers Limited (Capitol Specialty Insurance Corporation v. Amtrust International Under Writers Limited) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Capitol Specialty Insurance Corporation v. Amtrust International Under Writers Limited, (S.D. Cal. 2019).

Opinion

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7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 CAPITOL SPECIALTY INSURANCE Case No. 3:18-cv-707-L-WVG CORPORATION, 12 ORDER GRANTING MOTION Plaintiff, TO STAY 13 v. 14 AMTRUST INTERNATIONAL 15 UNDERWRITERS LIMITED, et al., 16 Defendants; _____________________________________ 17 AND RELATED COUNTERCLAIMS 18 AND CROSS-CLAIMS.

19 20 Pending before the Court in this insurance action is a motion to stay filed by 21 Defendants and Cross-Defendants McAvoy Construction, Inc. and Russell McAvoy 22 (collectively "McAvoy"). Plaintiff/Counter-Defendant Capitol Specialty Insurance 23 Corporation ("Capitol") and Defendant/Counterclaimant/Cross-Claimant AmTrust 24 International Underwriters Limited ("AmTrust," collectively "Insurers") each filed 25 an opposition. McAvoy replied. For the reasons which follow, McAvoy's motion 26 to stay is granted. 27 / / / / / 28 1 In May 2013, McAvoy was retained by the Ellen Joy Marks Trust ("Marks") 2 as a general contractor on a custom residential project located in San Diego. The 3 project was to pass final inspection and be substantially completed around 4 September 2014. Due to alleged faulty work, the final inspection did not take place 5 until November 2015. In March 2016, Ms. Marks moved into the residence 6 although the project was still not completed. In addition to prior defective work 7 which had not been remedied, after moving in, Ms. Marks discovered new defects. 8 She also found that major and minor work remained to be done. On August 11, 9 2016, she sent a notice of breach and a demand to cure to McAvoy. On November 10 14, 2016, she filed a construction defect lawsuit in state court captioned Marks v. 11 McAvoy Construction, Inc. et al., San Diego County Superior Court case no. 37- 12 2016-00039955-CU-BC-CTL, alleging breach of contract, breach of the implied 13 covenant of good faith and fair dealing, building code violations, negligence and 14 accounting (the "Underlying Action"). She produced a 23-page list of defects 15 which she attributed to McAvoy and its numerous subcontractors. 16 McAvoy tendered the defense of the Underlying Action to its Insurers. 17 AmTrust had issued commercial general liability policies to McAvoy with effective 18 dates of June 30, 2014 to June 30, 2016. Capitol had issued a commercial general 19 liability policy with effective dates of May 6, 2016 to May 6, 2017. Capitol agreed 20 to defend McAvoy with a reservation of rights. 21 Shortly thereafter, Capitol filed the instant action against McAvoy and 22 AmTrust seeking a declaratory judgment of no duty to defend and no duty to 23 indemnify McAvoy, declaratory judgment that AmTrust had a duty to defend, as 24 well as equitable contribution and indemnity from AmTrust. After this action was 25 filed, AmTrust agreed to defend McAvoy in the Underlying Action and reimburse 26 Capitol for an equitable share of the defense costs, both with a reservation of rights. 27 In this action, AmTrust cross-claimed against McAvoy seeking a declaratory 28 1 judgment of no duty to defend and no duty to indemnify and reimbursement of 2 defense costs. AmTrust also counterclaimed against Capitol seeking a declaratory 3 judgment of no duty to defend and no duty to indemnify as well as equitable 4 contribution. The Court has diversity jurisdiction over all claims pursuant to 28 5 U.S.C. §1332. 6 McAvoy filed the pending motion requesting the Court to stay this action 7 pending the resolution of the Underlying Action. The motion is based primarily on 8 the overlap in factual issues and duplicative discovery. Both Insurers oppose. 9 Although they concede that liability and coverage actions always entail a certain 10 amount of factual overlap, they argue that this action should not be stayed. At the 11 very least, they claim, they should be allowed to file summary judgment motions on 12 the duty to defend issues, which, according to them, can be resolved completely 13 separate and apart from the Underlying Action. 14 The Declaratory Judgment Act, 28 U.S.C. §2201, confers on federal courts 15 unique and substantial discretion in deciding whether to declare the 16 rights of litigants. On its face, the statute provides that a court "may declare the rights and other legal relations of any interested party 17 seeking such declaration” . . .. The statute's textual commitment to 18 discretion, and the breadth of leeway . . . distinguish the declaratory judgment context from other areas of the law in which concepts of 19 discretion surface. [It is] an enabling Act, which confers a discretion 20 on the courts rather than an absolute right upon the litigant.

21 Wilton v. Seven Falls Co., 515 U.S. 277, 286 (1995) (emphasis in original, quoting 22 28 U.S.C. §2201(a); other citations and internal quotation marks omitted). 23 "Consistent with the nonobligatory nature of the remedy, a district court is 24 authorized . . . to stay or dismiss an action seeking declaratory judgment." Id. at 25 288. As requested here, a stay is often preferable to dismissal "because it assures 26 that the federal action can proceed without risk of a time bar if the state case, for 27 any reason, fails to resolve the matter in controversy." Id. n.2. When parallel state 28 1 court proceedings are pending, "presenting an opportunity for ventilation of the 2 same state law issues," the district court may stay the case in federal court to allow 3 for completion of the state court case. Id. at 290 (discussing Brillhart v. Excess Ins. 4 Co. of Am., 316 U.S. 491 (1942)). "[F]ederal courts should generally decline to 5 entertain reactive declaratory actions." R.R. Street & Co. Inc. v. Transport Ins. Co., 6 656 F.3d 966, 976 (9th Cir. 2011). Three factors first articulated in Brillhart bear 7 upon the decision whether to stay (or dismiss) a declaratory relief action: avoiding 8 needless determination of state law issues; discouraging forum shopping; and 9 avoiding duplicative litigation. Id. at 975. 10 The pending action presents insurance coverage and contribution issues 11 while the Underlying Action presents liability issues. All claims are asserted under 12 California law. Neither the parties named, nor the legal claims alleged in the 13 Underlying Action and in this coverage action are identical. The Insurers latch on 14 to this and claim that at least the duty to defend issues are independent of the issues 15 raised in the Underlying Action. In their opposition briefs both Insurers point to 16 their respective definitions of occurrence and pre-existing occurrence exclusions, 17 arguing that the timing of the alleged damage is central to their duty to defend 18 claims while irrelevant to any claims raised in the Underlying Action. 19 The Insurers' opposition is based on an oversimplified view of construction 20 defect litigation, especially in light of the 23-page list of defects produced by 21 Marks, which attributes the defects not only to McAvoy but also to its numerous 22 subcontractors. It is beyond question that the Underlying Action will entail 23 litigation of each alleged defect. It seems patently unnecessary to cover the same 24 ground in this action, even if, as Insurers contend, all they are interested in in this 25 action is the timing of each defect.

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Capitol Specialty Insurance Corporation v. Amtrust International Under Writers Limited, Counsel Stack Legal Research, https://law.counselstack.com/opinion/capitol-specialty-insurance-corporation-v-amtrust-international-under-casd-2019.