Carpenter v. Twin City Fire Insurance Company

CourtDistrict Court, N.D. Texas
DecidedFebruary 2, 2024
Docket3:23-cv-00769
StatusUnknown

This text of Carpenter v. Twin City Fire Insurance Company (Carpenter v. Twin City Fire Insurance Company) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carpenter v. Twin City Fire Insurance Company, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

JEFFREY W. CARPENTER, § § Plaintiff, § § v. § Civil Action No. 3:23-CV-0769-N § TWIN CITY FIRE INSURANCE CO., § § Defendant. §

MEMORANDUM OPINION AND ORDER

This Order addresses Defendant Twin City Fire Insurance Co.’s (“Twin City”) partial motion to dismiss [34] Plaintiff Jeff Carpenter’s claims for punitive damages and injunctive relief. Because Carpenter has not and cannot adequately establish standing to assert these claims, the Court grants Twin City’s motion and dismisses Carpenter’s claims with prejudice. I. ORIGINS OF THE MOTION This case arises out of a Stowers claim1 brought by Plaintiff Jeff Carpenter against Defendant Twin City Fire Insurance Company. In a separate case, Carpenter sued his employer for an unrelated cause of action. Pl.’s Original Petition at ¶ 2 [1-2]. Carpenter’s employer was insured by Twin City. Id. at ¶ 17. Carpenter offered to settle his case against his employer within the limits of his employer’s insurance policy with Twin City, but Twin

1 A Stowers claims arises when an insurer violates its duty to settle third-party claims against its insureds when it would be reasonably prudent to accept the settlement. In re Farmers Tex. Cnty Mut. Ins. Co., 621 S.W.3d 261, 267 (Tex. 2021). The duty was first recognized in G.A. Stowers Furniture Co. v. Am. Indem. Co., 15 S.W.2d 544 (Tex. Comm'n App. 1929, holding approved). City declined the settlement offer. Id. at ¶ 34–36. Carpenter then won at trial against his employer, and the jury awarded damages that exceeded the limits of the insurance policy. Id. at ¶ 36. This gave rise to the Stowers claim at issue in the present litigation. As part of

the judgment against Carpenter’s employer, the court in that proceeding assigned the employer’s Stowers claim to Carpenter via turnover order. Id. at ¶ 4. Carpenter then initiated the present proceeding against Twin City, bringing the assigned Stowers claim as well as seeking punitive damages and injunctive relief. Twin City removed the case to federal court. Notice of Removal [1]. Twin City now moves to dismiss two of Carpenter’s

three claims under Rule 12(b)(1) for lack of standing, or alternatively, under Rule 12(c) for failure to adequately state a claim. II. LEGAL STANDARD UNDER RULE 12(B)(1) Under the United States Constitution, a federal court may decide only actual “cases” or “controversies.” U.S. CONST. art. III, § 2. A court properly dismisses a case where it

lacks the constitutional power to decide it. Home Builders Ass'n of Miss., Inc. v. City of Madison, 143 F.3d 1006, 1010 (5th Cir. 1998). “The justiciability doctrines of standing, mootness, political question, and ripeness all originate in Article III's ‘case’ or ‘controversy’ language.” Choice Inc. of Tex. v. Greenstein, 691 F.3d 710, 715 (5th Cir. 2012) (quoting Daimler Chrysler Corp. v. Cuno, 547 U.S. 332, 352, (2006)) (internal

quotation marks omitted). “Standing and ripeness are required elements of subject matter jurisdiction and are therefore properly challenged on a Federal Rule of Civil Procedure 12(b)(1) motion to dismiss.” Roman Catholic Diocese of Dallas v. Sebelius, 927 F.Supp.2d 406, 415–16 (N.D. Tex. 2013) (citing Xerox Corp. v. Genmoora Corp., 888 F.2d 345, 350 (5th Cir. 1989); Western Geco L.L.C. v. Ion Geophysical Corp., 776 F.Supp.2d 342, 350 (S.D. Tex. 2011)).

A dismissal for lack of subject-matter jurisdiction is warranted when “it appears certain that the plaintiff cannot prove any set of facts in support of his claim that would entitle the plaintiff to relief.” Ramming v. United States, 281 F.3d 158, 161 (5th Cir. 2001). “In general, where subject matter jurisdiction is being challenged, the trial court is free to

weigh the evidence and resolve factual disputes in order to satisfy itself that it has the power to hear the case.” Montez v. Dep't of Navy, 392 F.3d 147, 149 (5th Cir. 2004). “Lack of subject matter jurisdiction may be found in any one of three instances: (1) the complaint alone; (2) the complaint supplemented by undisputed facts evidenced in the record; or (3) the complaint supplemented by undisputed facts plus the court's resolution of disputed

facts.” Ramming, 281 F.3d at 161. The standing requirement has three elements: (1) injury in fact, (2) causation, and (3) redressability. See Bennett v. Spear, 520 U.S. 154, 167 (1997). The injury cannot be merely “conjectural or hypothetical.” Summers v. Earth Island Inst., 555 U.S. 488, 493

(2009). Causation requires that the injury “fairly can be traced to the challenged action of the defendant” rather than to “the independent action of some third party not before the court.” Simon v. E. Ky. Welfare Rights Org., 426 U.S. 26, 41-42 (1976). And redressability requires that it is likely, “as opposed to merely ‘speculative,’ that the injury will be ‘redressed by a favorable decision.’” Lujart v. Defs. of Wildlife, 504 U.S. 555, 561 (1992) (quoting Simon, 426 U.S. at 38, 43). The party invoking federal subject matter jurisdiction bears the burden of establishing each element. Ramming, 281 F.3d at 161.

III. LEGAL STANDARD UNDER RULE 12(C) Rule 12(c) provides that “[a]fter the pleadings are closed—but early enough not to

delay trial—a party may move for judgment on the pleadings.” FED. R. CIV. P. 12(c). A Rule 12(c) motion “is designed to dispose of cases where the material facts are not in dispute and a judgment on the merits can be rendered by looking to the substance of the pleadings and any judicially noticed facts.” Great Plains Tr. Co. v. Morgan Stanley Dean Witter & Co., 313 F.3d 305, 312 (5th Cir. 2002) (citation and internal quotation marks omitted). The court may also consider documents attached to the complaint. See Voest-

Alpine Trading USA Corp. v. Bank of China, 142 F.3d 887, 891 n.4 (5th Cir. 1998). The pleading standard for a Rule 12(c) motion is the same as for a motion to dismiss under Rule 12(b)(6). Doe v. MySpace, Inc., 528 F.3d 413, 418 (5th Cir. 2008).

IV. THE COURT GRANTS THE PARTIAL MOTION TO DISMISS BECAUSE CARPENTER DOES NOT HAVE STANDING TO PROCEED WITH TWO OF HIS CLAIMS

The Court finds that Carpenter does not have standing to assert his claims for punitive damages and injunctive relief because the turnover order granted him standing to proceed only with his Stowers claim, and he has failed to establish independent standing to bring any other claim. Accordingly, the Court grants Twin City’s partial motion to dismiss. A.

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Montez v. Department of the Navy
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528 F.3d 413 (Fifth Circuit, 2008)
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DaimlerChrysler Corp. v. Cuno
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691 F.3d 710 (Fifth Circuit, 2012)
Westerngeco L.L.C. v. Ion Geophysical Corp.
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Carpenter v. Twin City Fire Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carpenter-v-twin-city-fire-insurance-company-txnd-2024.