Carrillo v. The Standard Fire Insurance Company

CourtDistrict Court, W.D. Washington
DecidedAugust 29, 2023
Docket3:23-cv-05583
StatusUnknown

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

Bluebook
Carrillo v. The Standard Fire Insurance Company, (W.D. Wash. 2023).

Opinion

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6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 SHERMAN CARRILLO, CASE NO. 3:23-cv-05583-RJB 11 Plaintiff, ORDER ON PLAINTIFF’S 12 v. MOTION TO REMAND 13 THE STANDARD FIRE INSURANCE COMPANY, doing business as 14 TRAVELERS INSURANCE, a foreign corporation doing business in Washington, 15 Defendant. 16 17 This matter comes before the Court on the Plaintiff’s Motion to Remand Case to State 18 Court. Dkt. 10. The Court has considered the pleadings filed regarding the motion and the 19 remaining file. 20 On May 5, 2023, the Complaint in this insurance dispute case was filed in Clark County, 21 Washington Superior Court. Dkt. 2 at 2. It alleges that the Defendant insurance company failed 22 to properly pay the Plaintiff, its insured, Personal Injury Protection (“PIP”) loss of income 23 benefits after a car accident. Id. The Complaint maintains that the Defendant miscalculated 24 1 Plaintiff’s “income loss benefits by $9,201.40” and refused to correct its error. Id. at 5. The 2 Plaintiff asserts claims for breach of contract, breach of the common law duty to act in good 3 faith, violations of Washington’s Insurance Fair Conduct Act, RCW 48.30, et. seq. (“IFCA”), 4 and violations of Washington’s Consumer Protection Act, RCW 19.86, et. seq, (“CPA”). Id. 5 The Plaintiff sought damages, attorneys’ fees and costs. Id.

6 The Complaint was served on the Washington State Insurance Commissioner on May 22, 7 2023. Id. Counsel for Defendant appeared in state court on June 1, 2023. Dkt. 2-4 at 2. On June 8 29, 2023, the Defendant removed the case to this Court. Dkt. 1. Asserting that this Court has 9 diversity jurisdiction under 28 U.S.C. § 1332, the Notice of Removal maintains that the parties 10 are citizens of different states and that the amount in controversy exceeds $75,000. Id. 11 The Plaintiff now moves the Court for an order remanding the case to state court. Dkt. 12 10. He contends that removal was untimely and that the Defendant failed to carry its burden to 13 demonstrate that the amount in controversy exceeds $75,000. Id. The Plaintiff moves for 14 attorneys’ fees as a result of having to file the motion. Id. The Defendant opposes the motion.

15 Dkt. 16. The Plaintiff has filed a reply (Dkt. 21) and the motion is ripe for review. 16 Also pending in this case is the Defendant’s motion to dismiss which is noted for 17 consideration on September 15, 2023. Dkts. 12 and 22. The Defendant contends that the case 18 must be dismissed because the Plaintiff has improperly named “The Standard Fire Insurance 19 Company, doing business as Travelers Insurance” when The Standard Fire Insurance Company 20 does not do business as Travelers Insurance. Id. The Defendant maintains that the Plaintiff’s 21 policy lists “The Standard Fire Insurance Company” as the “insurer” and his automobile 22 insurance card lists “The Standard Fire Insurance Company” as the “insurer.” Id. 23 24 1 While the Defendant argues that the Court should not decide the motion to remand before 2 the motion to dismiss is decided, it fails to demonstrate why. There is no showing that the 3 caption could not be easily amended, if warranted. This Court’s jurisdiction over the case should 4 be determined in the first instance. The Plaintiff’s motion for remand and for an award of 5 attorneys’ fees should be decided forthwith.

6 For the reasons provided below, the motion to remand this case should be granted. This 7 Court does not have jurisdiction over the case. The Plaintiff’s motion for attorneys’ fees and 8 costs should be denied. This case should be remanded to Clark County, Washington Superior 9 Court and all remaining motions should be stricken, to be renoted in state court if appropriate. 10 DISCUSSION 11 Federal courts are courts of limited jurisdiction that possess only that power authorized 12 by the Constitution and federal statutes. Negrete v. City of Oakland, 46 F.4th 811, 816 (9th Cir. 13 2022). A defendant may remove a civil action brought in state court when the district court has 14 original jurisdiction. 28 U.S.C. § 1441(a). Removal statutes are to be construed narrowly in

15 favor of remand to protect the jurisdiction of state courts. Cnty. of San Mateo v. Chevron Corp., 16 32 F.4th 733, 764 (9th Cir. 2022). “Federal jurisdiction must be rejected if there is any doubt as 17 to the right of removal in the first instance.” Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 18 1992). 19 The removal of civil cases from state court to federal court is governed by 28 U.S.C. § 20 1446, which provides that a “notice of removal of a civil action or proceeding shall be filed 21 within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the 22 initial pleading setting forth the claim for relief upon which such action or proceeding is based.” 23 28 U.S.C. § 1446(b)(1). “A defendant’s time to remove is triggered by simultaneous service of 24 1 the summons and complaint, or receipt of the complaint, through service or otherwise, after and 2 apart from service of the summons, but not by mere receipt of the complaint unattended by any 3 formal service.” Murphy Bros., Inc. v. Michetti Pipe Stringing, Inc., 526 U.S. 344, 347 (1999). 4 A. REMAND BASED ON TIMELINESS 5 The Plaintiff moves to remand the case, arguing that removal was not timely. Dkt. 10.

6 He asserts that under Washington law, service on the Defendant was effectuated on May 22, 7 2023 when he served the Washington State Insurance Commissioner. Id. The Defendant 8 contends that it received notice of this lawsuit on June 1, 2023. Dkt. 18 at 1. Accordingly, it 9 maintains, removal on June 29, 2023 was within the 30-day window permitted by § 1446. Id. 10 Resolving this issue turns on when the Defendant is deemed to have been served - the 11 sufficiency of the service of process. “The sufficiency of service of process prior to removal is 12 strictly a state law issue.” Lee v. City of Beaumont, 12 F.3d 933, 937 (9th Cir. 1993), overruled 13 on other grounds by Cal. Dep't of Water Resources v. Powerex Corp., 533 F.3d 1087 (9th Cir. 14 2008). Under Washington law:

15 Each authorized foreign or alien insurer must appoint the commissioner as its attorney to receive service of, and upon whom must be served, all legal process 16 issued against it in this state upon causes of action arising within this state. Service upon the commissioner as attorney constitutes service upon the insurer. 17 Service of legal process against the insurer can be had only by service upon the commissioner, except actions upon contractor bonds pursuant to RCW 18.27.040, 18 where service may be upon the department of labor and industries.

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Carrillo v. The Standard Fire Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carrillo-v-the-standard-fire-insurance-company-wawd-2023.