Chitty v. State Farm Mutual Automobile Insurance

36 F.R.D. 37, 8 Fed. R. Serv. 2d 34, 1964 U.S. Dist. LEXIS 9851
CourtDistrict Court, E.D. South Carolina
DecidedAugust 25, 1964
DocketNo. AC-1408
StatusPublished
Cited by30 cases

This text of 36 F.R.D. 37 (Chitty v. State Farm Mutual Automobile Insurance) is published on Counsel Stack Legal Research, covering District Court, E.D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chitty v. State Farm Mutual Automobile Insurance, 36 F.R.D. 37, 8 Fed. R. Serv. 2d 34, 1964 U.S. Dist. LEXIS 9851 (southcarolinaed 1964).

Opinion

SIMONS, District Judge.

This matter comes before me on motions of the plaintiff hereinafter referred to as Chitty, to require the production of certain documents by the defendant, hereinafter referred to as State Farm, and to dismiss State Farm’s Counterclaim; and on Motion of State Farm to vacate the Notice of Taking certain Depositions on behalf of Chitty or, in the alternative, to limit the depositions to specific written interrogatories. Argument on these Motions was heard by this Court at Aiken on June 29, 1964, and both parties thereafter filed Briefs with the Court.

This is an action instituted by Chitty against State Farm for negligence and [39]*39bad faith in failing to settle an earlier suit brought against Chitty1 2in which a verdict was rendered in excess of the liability insurance coverage which Chitty had purchased from State Farm. In the earlier action, in accordance with the provisions of its liability insurance policy, State Farm employed counsel to represent Chitty in that action, and herein she has moved the Court to require State Farm to produce its files in the former action, including all correspondence between State Farm and counsel employed by it to represent Chitty in said former action.

State Farm opposes Motion to Produce under provisions of Rule 84, which requires moving party to prove relevancy of documents, as well as good cause for their production; and upon further ground that information sought by Chitty is privileged because of attorney-client relationship existing between State Farm and its attorneys in the former action.

The gravamen of Chitty’s Complaint is that State Farm was negligent, reckless, guilty of bad faith, and acted in its own interest in handling the defense and in not settling the prior tort action against her, when it had the opportunity to do so, and was urged by Chitty to do so, within her policy limits. State Farm’s failure to settle the case resulted in an excess verdict against her in the sum of Twenty-five Thousand [$25,000.00] Dollars.

Under Rule 34 of Federal Rules of Civil Procedure, 28 U.S.C.A 2 Chitty must show, not only that the documents, facts and information sought are relevant, but also that good cause exists for their production, and that they are “not privileged”. Guilford National Bank of Greensboro v. Southern Rwy. Co., 297 F.2d 921 [4th Cir.].

Chitty contends that she should be permitted to inspect the documents and records in State Farm’s files of the prior case which are specified in her Motion to Produce 3 in order to determine what investigation State Farm made of the case, whether it rejected advice and recommendations of its own agents, adjusters and attorneys. The Court finds that such records and documents are relevant and that good cause has been shown for their production. In Bell v. Commercial Ins. Co. of Newark, N. J., 280 F.2d 514 [3rd Cir. 1960] the Court said:

“With respect to the discovery sought under Rule 34, of the insurer’s records pertaining to the personal injury action, we entertain no doubt but that it should have been permitted. Practically, the insurer is in an unenviable position. While it prefers to maintain the privacy of its communications and records, its [40]*40failure to make them available certainly permits inferences against the company by judge and jury. It can hardly be denied that, whether such records would be admissible as evidence, they are relevant and germane, could reasonably lead to the discovery of admissible evidence, and would certainly be of assistance to Bell in the preparation of his case. We do not mean this to be a categorical statement as to what constituted ‘good cause’ under the Rule. But coupling these with the ‘agency relationship’ existing between the insured and the insurer as indicated by the Court in the Cowden case, which alone would seem to furnish adequate ground for compelling the discovery, leads us to the conclusion that Bell was and is entitled the discovery requested.”

An exhaustive annotation as to the duty of liability insurer to settle or compromise is contained in 40 A.L.R.2d pages 168-226, and many cases are cited which substantiate Chitty’s contention that her inquiries here are relevant to the issues.

Whether State Farm properly investigated the case, whether it sought and followed advice and recommendation of its agents, adjusters and attorneys, are facts which are surely relevant to the issue of its negligence, recklessness, and bad faith in not settling the prior case. Evidence of these matters, if any exists, are in the files of State Farm and may be quite necessary as proof of an unreasonable and arbitrary attitude on the part of State Farm in not settling the cases when advised to do so. Such evidence is not otherwise available to Chitty in advance of trial. She cannot properly prepare and try her case without this information; the denial of her Motion will result in hardship and prejudice; and the production of such items will aid substantially in proving her cause of action, if she has one.4

Even though the Court finds that the information requested is relevant, and that good cause has been shown for its production, is such information “not privileged” under the purview of Rule 34 ? This question has caused the Court its greatest concern in this case. Surely the privilege of attorney-client relationship is a time honored right and should be preserved; neither should the “work product” of an attorney be made available to an adverse party, as a matter of right, without a proper showing of necessity or good cause. Hickman, Adm. v. Taylor, et al., 329 U.S. 495, 67 S.Ct. 385, 91 L.Ed. 451 [1946]5

State Farm relies on the Hickman case in support of its position that Chitty should be denied the information sought from its files. The Court does not feel that this case is controlling under the factual situation presented here. The papers and writings which Chitty seeks are not related to or were not prepared by its attorneys for the present action between State Farm and Chitty. These papers were prepared in a differ[41]*41ent action at an earlier time when the same attorneys represented both State Farm and Chitty. It has been held that, where two parties are represented by the same attorneys for their mutual benefit, the communications between the parties are not privileged in a later action between such parties or their representatives. England v. England, 243 Iowa 274, 51 N.W.2d 437. See cases cited in annotation in 22 A.L.R.2d 659 at pages 662-664; 58 Am.Jur. Witnesses, § 496.

The Supreme Court of Wisconsin has held that an attorney may properly act as an attorney for both parties to a transaction with the full knowledge and consent of both, but when a conflict of interest arises in the matter, he must make full disclosures to both or terminate the relation of attorney and client as to both. State v. Rogers, 226 Wis. 39, 275 N.W. 910, 914.

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Bluebook (online)
36 F.R.D. 37, 8 Fed. R. Serv. 2d 34, 1964 U.S. Dist. LEXIS 9851, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chitty-v-state-farm-mutual-automobile-insurance-southcarolinaed-1964.