Carlo J. Smith v. Safeway Insurance Company

CourtCourt of Appeals of Mississippi
DecidedAugust 4, 2020
DocketNO. 2019-CA-01171-COA
StatusPublished

This text of Carlo J. Smith v. Safeway Insurance Company (Carlo J. Smith v. Safeway Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carlo J. Smith v. Safeway Insurance Company, (Mich. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2019-CA-01171-COA

CARLO J. SMITH APPELLANT

v.

SAFEWAY INSURANCE COMPANY APPELLEE

DATE OF JUDGMENT: 07/12/2019 TRIAL JUDGE: HON. TOMIE GREEN COURT FROM WHICH APPEALED: HINDS COUNTY CIRCUIT COURT, FIRST JUDICIAL DISTRICT ATTORNEYS FOR APPELLANT: DESHUN T. MARTIN DENISE C. WESLEY SAMAC S. RICHARDSON VATERRIA M. MASON ATTORNEY FOR APPELLEE: GOODLOE T. LEWIS NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: REVERSED AND REMANDED - 08/04/2020 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE BARNES, C.J., McDONALD AND McCARTY, JJ.

McCARTY, J., FOR THE COURT:

¶1. A driver sued a woman and her daughter in a county court after the daughter rear-

ended him in a car wreck. The woman’s insurance company denied responsibility to provide

coverage for the accident and sought a declaratory judgment in the circuit court against the

woman, her daughter, and the other driver. The woman and her daughter never responded

to the complaint, and a default judgment was entered against them. The injured driver

responded and claimed the insurance company was responsible for covering the accident.

1 Nonetheless, the circuit court found the driver’s dispute was moot because the insured and

her daughter had essentially confessed that there was no coverage. The circuit court granted

a declaratory judgment in favor of the insurance company.

¶2. Because an actual controversy exists between the injured driver and the insured

company, we reverse and remand.

FACTS AND PROCEDURAL HISTORY

¶3. Teenaged Madison Brown rear-ended Carlo Smith. Her mother, Altheia Tribble,

owned the car the teenager was driving at the time of the accident. Smith sued them both in

the County Court of Hinds County.

¶4. Tribble was insured by Safeway Insurance Company. The lawsuit prompted Safeway

to file its own complaint to obtain a declaratory judgment against Tribble, Brown, and Smith

in the circuit court. Safeway argued that it was not required to provide coverage because

Tribble had never listed her daughter as a driver on the original application or any of the

renewal forms.

¶5. The mother and daughter failed to answer the complaint. The circuit clerk entered an

entry of default against them, which was followed by a default judgment by the circuit court.

Although Tribble and her daughter failed to answer the complaint for a declaratory judgment,

Smith timely answered and litigated against Safeway for coverage. The heated litigation

included dueling motions for summary judgment by both the insurer and the injured driver.

¶6. Subsequently, Safeway sought leave to amend its initial complaint for a declaratory

2 judgment to add two additional parties who were involved in Smith’s car accident. The

addition of the two parties was the only difference between Safeway’s original complaint and

its amended complaint. The trial court granted the motion, and Safeway filed its amended

complaint.

¶7. Although he had timely answered the original complaint, Smith did not timely answer

the amended complaint. As it had done against the mother and daughter, Safeway sought an

entry of default. Smith responded by filing a motion to strike Safeway’s request for an entry

of default, listing what he insisted were “colorable defenses” for his untimeliness. He then

filed an answer to the insurer’s amended complaint. Nonetheless, the circuit clerk entered

a default against Smith. Smith then filed a motion to set aside the entry of default, listing a

slew of defenses to support his motion. The circuit court never ruled on his request to set

aside the entry of default.

¶8. After a hearing, the circuit court granted Safeway’s request for a declaratory

judgment. However, it did not rule on any of the arguments presented to it. Instead, the

holding focused entirely on the mother and daughter’s failure to answer Safeway’s

complaint. The trial court held that because they failed to answer, the mother and daughter

“[e]ssentially . . . agreed that there [was] no insurance coverage under Tribble’s Safeway

policy that covere[d] the actions of Madison Brown.”

¶9. In the circuit court’s view, this “agreement” terminated the dispute. It specifically

ruled that “[s]uch finding makes moot any claim Defendant Carlo Smith may assert in this

3 action.”

¶10. The circuit court concluded by declaring that its ruling did not affect Smith’s pending

county court case against the mother and daughter. It did not address any other issues,

motions, or entries of default. The docket reflected that the pending motions for summary

judgment as well as other motions were all found moot. Smith appealed.

ANALYSIS

¶11. In this case, the trial court determined that Smith’s claims were moot because the

mother and daughter did not respond to the request for a declaratory judgment. We apply “a

de novo standard of review to questions of law, including a motion for a declaratory

judgment.” S.C. Ins. Co. v. Keymon, 974 So. 2d 226, 229 (¶9) (Miss. 2008).

¶12. “The doctrine of mootness demands that a case must have an ‘actual controversy’ that

existed at the time of trial.” Kemper City v. Parks, 281 So. 3d 208, 209 (¶7) (Miss. Ct. App.

2019) (quoting Monaghan v. Blue Bell Inc., 393 So. 2d 466, 466 (Miss. 1980)). “Without

a live controversy, an appeal will be dismissed as moot.” Butler Snow LLP v. Estate of

Mayfield, 281 So. 3d 1214, 1218 (¶13) (Miss. Ct. App. 2019).

¶13. Safeway sought a declaratory judgment under Mississippi Rule of Civil Procedure 57.

This is permissible because “Rule 57 specifically provides for declaratory judgment to

determine questions of contractual validity and interpretation.” Wood v. Safeway Ins. Co.,

114 So. 3d 714, 717 n.2 (Miss. 2013). The Rule states in relevant part that “[a]ny person

interested under a . . . written contract . . . may have determined any question of construction

4 or validity arising under the . . . contract . . . and obtain a declaration of rights, status or other

legal relations thereunder.” MRCP 57(b)(1).

¶14. Furthermore, the Rule expressly allows a party like Smith to seek a declaratory

judgment. Specifically, Rule 57(b)(2) states that “[w]here an insurer has denied or indicated

that it may deny that a contract covers a party’s claim against an insured, that party may seek

a declaratory judgment construing the contract to cover the claim.” MRCP 57(b)(2).

Because Safeway is denying that its contract covers Smith’s claim against the insured, Smith

may seek a declaratory judgment “construing the contract to cover the claim” under Rule 57.

Id.

¶15. Our jurisprudence confirms Smith has standing to seek a declaratory judgment. In

recently interpreting a similar subsection of the rule, this Court examined a dispute where a

party claimed a subsequent purchaser for land did not have standing because of lack of

privity of contract with prior owners of the property. Putney v. Sanford, 282 So. 3d 627, 631

(¶13) (Miss. Ct. App. 2019). Citing Rule 57, we rejected this argument. Id. at 631-32 (¶¶15-

17). Both sides were fighting over title to the same 196 acres of land. Id. at 629 (¶6). The

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Related

Johnson v. Hinds County
524 So. 2d 947 (Mississippi Supreme Court, 1988)
South Carolina Ins. Co. v. Keymon
974 So. 2d 226 (Mississippi Supreme Court, 2008)
Monaghan v. Blue Bell
393 So. 2d 466 (Mississippi Supreme Court, 1980)
Wood v. Safeway Insurance Co.
114 So. 3d 714 (Mississippi Supreme Court, 2013)

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Carlo J. Smith v. Safeway Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carlo-j-smith-v-safeway-insurance-company-missctapp-2020.