Carrier, et al. v. American Bankers

2008 DNH 031
CourtDistrict Court, D. New Hampshire
DecidedFebruary 1, 2008
Docket05-CV-430-JD
StatusPublished

This text of 2008 DNH 031 (Carrier, et al. v. American Bankers) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carrier, et al. v. American Bankers, 2008 DNH 031 (D.N.H. 2008).

Opinion

Carrier, et a l . v. American Bankers 05-CV-430-JD 02/01/08 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Lori Carrier and Valerie Whitman

v. Civil No. 05-CV-430-JD Opinion No. 2008 DNH 031

American Bankers Life Assurance Co. of Florida

O R D E R

Lori Carrier and Valerie Whitman filed a putative class

action, alleging that American Bankers Life Assurance Company of

Florida breached the terms of its credit insurance policies with

them and other putative class members when it failed to refund

the unearned portion of premiums that had been prepaid as part of

their vehicle financing. Carrier and Whitman move for class

certification. American Bankers opposes the motion.

Standard of Review

The circuits differ on the standard of proof necessary to

support a motion for class certification. See In re Initial Pub.

Offering Sec. Litiq., 471 F.3d 24, 38-40 (2d Cir. 2006)

(discussing law in the circuits). The First Circuit follows the

majority view, holding that "a district court must conduct a

rigorous analysis of the prerequisites established by Rule 23 before certifying a class."1 In re PolvMedica Corp. Sec. Litiq..

432 F.3d 1, 6 (1st Cir. 2005) (internal quotation marks omitted).

In doing so, a district court may resolve disputed factual issues

that arise in the course of class certification by considering

materials beyond the pleadings. Id.

Background

Carrier and Whitman each purchased a car at a dealership in

New Hampshire on credit. As part of their car financing

arrangements. Carrier and Whitman also purchased credit

disability insurance issued by American Bankers through the car

dealerships. They paid a single premium that was included in

their vehicle financing when they bought their cars. Both paid

off the loans before the due dates.

The American Bankers insurance policies issued to Carrier

and Whitman provide that "[a]ny unearned premium will be: (1)

credited to the insured's account, if financed, or paid to the

insured; and (2) computed by the formula on file and approved by

the Insurance Commissioner." Neither Carrier nor Whitman

received a refund or credit for the part of the premium that

would have covered the remainder of the financing period after

1Although the issue arises most frequently in securities fraud litigation, neither the First Circuit nor other circuits have limited the analysis to that context.

2 they prepaid their loans.

Carrier and Whitman brought suit, as a putative class

action, against American Bankers, alleging that American Bankers

breached the term of its insurance policies that promised to

refund the unearned part of the premium each of them paid and

breached the implied covenant of good faith and fair dealing.

They also seek a declaratory judgment that American Bankers is

obligated to refund unearned premiums to its insureds.

In their motion for class certification. Carrier and

Whitman, as class representatives, propose the following class:

"All persons charged for American Bankers single premium credit

life and/or disability insurance; 1) produced by a motor vehicle

dealership located within IA, ID, KS, ME, MI, MT, ND, NH, NJ, OH,

OR, RI, or TX; 2) who paid off their credit-insured loans prior

to the coverage expiration date and within the applicable

limitations period; but 3) did not receive a refund of their

unearned premium." They also propose, but not as part of the

class definition, that those who bought insurance but

(1) who timely and properly request exclusion from the class; (3) [sic] who are present or former officers and directors of American Bankers; (4) whose credit insurance was rescinded by mutual consent of the parties or whose coverage was canceled by either the insured or the insurer prior to the prepayment date; (5) whose indebtedness was discharged in bankruptcy and not reaffirmed; (6) whose coverage was terminated because the collateral was repossessed; (7) who have signed contracts with American Bankers that contain a provision requiring arbitration of claims for unearned

3 premium; and (8) as to whom American Bankers has paid a claim

be excluded from the class.

Discussion

Carrier and Whitman seek to represent a class of people who

paid a single premium for credit insurance from American Bankers

when they purchased vehicles and then did not receive a refund of

the unearned part of the premium when they prepaid their loans.

They contend that the proposed class satisfies the requirements

of Federal Rule of Civil Procedure 23(a) and 23(b)(3). American

Bankers opposes class certification, arguing that the plaintiffs'

proposed class definition is defective and that the plaintiffs

cannot satisfy the requirements of Rule 23(a) or Rule 23(b)(3).

"To obtain class certification, the plaintiff must establish

the four elements of Rule 23(a) and one of [the] several elements

of Rule 23(b)." Smilow v. Southwestern Bell Mobile Sv s ., Inc..

323 F.3d 32, 38 (1st Cir. 2003). For purposes of class

certification, the court does not decide whether the plaintiffs

will prevail on the merits of their claims but may consider the

probable course of the case to "'formulate some prediction as to

how specific issues will play out in order to determine whether

common or individual issues predominate.'" In re PolvMedica. 432

F.3d at 6 (quoting Waste M q m t . Holdings. Inc. v. Mowbrav. 208

4 F .3d 288, 298 (1st Cir. 2 0 0 0 ) )

I. Oral Argument

Carrier and Whitman move for oral argument on the motion for

class certification. The rule in this district is that

ordinarily the court will decide motions without oral argument.

LR 7.1(d). The court may allow argument if a party shows, in a

written statement, that it would provide assistance to the court

in deciding the motion. Id.

In support of their motion. Carrier and Whitman contend that

oral argument would assist the court in deciding class

certification because they "would be available to respond to any

concerns the Court may have pertaining to the mechanics and

procedures for obtaining payoff dates to verify class membership

and quantify damages." Mot. at 1. Counsel for American Bankers

did not concur in the motion or file a response.

The court does not believe that oral argument on the issue

proposed by the plaintiffs would be of assistance in deciding the

motion for class certification.

II. Goulette Declaration

In a footnote, American Bankers challenges the declaration

of Aaron Goulette and the appendix to the declaration that

Carrier and Whitman filed in support of their motion for class

5 certification. American Bankers contends that the declaration is

double hearsay and that the appendix lacks authentication. In

addition, American Bankers disputes some of the information

provided in the declaration and appendix. Carrier and Whitman

argue that the rules of evidence do not apply at the class

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