Clark v. State Farm Mutual Automobile Insurance

131 A.3d 806, 2016 Del. LEXIS 10, 2016 WL 125432
CourtSupreme Court of Delaware
DecidedJanuary 11, 2016
Docket167, 2015
StatusPublished
Cited by27 cases

This text of 131 A.3d 806 (Clark v. State Farm Mutual Automobile Insurance) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clark v. State Farm Mutual Automobile Insurance, 131 A.3d 806, 2016 Del. LEXIS 10, 2016 WL 125432 (Del. 2016).

Opinion

STRINE, Chief Justice:

I. INTRODUCTION

Section 2118B(c) of Title 21 is the focus of this putative class action. The statute provides that an insurer “shall” process and either pay or deny a claim for motor vehicle insurance benefits within thirty days of the insurer’s receipt of such a request. 1 It also provides that “[i]f an insurer fails to comply with the [thirty-day requirement],” then the insurer must also pay the claimant interest at a rate that ranges from 1.5% to 2.5% per month depending on the length of the delay. 2

The plaintiffs both have policies with State Farm Mutual Automobile Insurance Company and both submitted claims that State Farm failed to pay within the statutory thirty-day period. The plaintiffs earlier alleged that State Farm had failed to make the required statutory interest payments to them and other claimants whose PIP claims had not been processed within thirty days. When that theory did not pan out and they faced summary judgment, the plaintiffs reformulated their pursuit of class-wide relief by proposing to file an amended complaint seeking a declaratory judgment from the Superior Court that State Farm must process all PIP claims within thirty days.

The Superior Court denied the motion for leave to amend, reasoning that amending the complaint would be futile because no case or controversy existed because the plaintiffs had been paid the required statutory interest. The court then granted summary judgment to State Farm.

On this appeal, the plaintiffs allege that the Superior Court was wrong to dismiss their claim, arguing that they have a ripe disagreement with State Farm over its failure to comply invariably with the thirty-day deadline set forth in § 2118B(e). *809 In this opinion, we affirm the Superior Court, but on a somewhat different ground. The plaintiffs are correct that absent declaratory (or injunctive) relief, it may be that they and other class members will have a claim in the future processed by State Farm in more than thirty days. But, we agree with the Superior Court that the amended complaint is futile because as plainly written, § 2118B(c) does not impose an invariable standard that every PIP claim must be processed within thirty days and, in fact, contemplates that will not be the case by establishing a statutory consequence for the failure to do so. On its face, § 2118B(c) does not leave room for a claim asking the Judiciary to affirmatively govern the operations of an insurer by dictating (in some form of complicated injunctive decree) that'it must process all claims within thirty days, that it must process most claims within thirty days, or that it must process all claims within thirty days except in judicially defined circumstances. The statute is not written in that manner, and to interpret it as leaving a huge gap to be filled by intrusive and legislatively unguided judicial regulation of the insurance industry as the plaintiffs assert would strain its words beyond reason and require our Judiciary to play an amorphous role that there is no indication the General Assembly intended for it. Under the Insurance Code, the Insurance Commissioner is empowered to investigate and enforce any violations of the Code. That role cannot be subsumed by the Judiciary in the guise of giving effect to § 2118B(c).

II. BACKGROUND 3

1. The Start Of Litigation

Rebecca Clark and' James Smith (the “Policyholders”) are named insureds under State Farm automobile insurance policies. Both filed claims for benefits on their PIP coverage with State Farm. State Farm began payments to Clark-on May 16, 2013 following her accident on January 24, 2013. It began payments to Smith ori'November 1, 2011 following his accident on September 9, 2011. 4 State Farm continued making payments to Clark and Smith through October 29, 2013 and February 11, 2014, respectively. Thus, both of the Policyholders received payments more than thirty days after submitting their claims, but they also received the statutorily required interest. On February 20,-2014, the Policyholders filed a Proposed Class Action Complaint against State Farm premised on State Farm’s alleged violations of §-2118B.

The plaintiffs’ original focus was on whether State Farm was'paying the full interest required when it processed payments after thirty days, and whether it was penalizing-policyholders by deducting the statutory interest from their'remaining policy limits. The complaint included four counts: (1) declaratory judgment; (2) breach of contract; (3) bad faith breach of contract; and (4) statutory consumer fraud. And the declaratory judgment theory was premised on the Policyholders’ argument that “State Farm has adopted the practice of deducting an amount equal to the statutory interest penalty from its insured’s limits of liability for PIP cover *810 age.” 5 But, that turned out not to be so.

Facing a motion for summary judgment because their original theory did not pan out, the Policyholders changed their focus and sought to file an amended complaint on August 20, 2014. The proposed amended complaint abandoned the Policyholders’ •original argument that State Farm routinely deducted the statutory interest from the PIP coverage limits that it owed the insured. The amended complaint sought only a declaratory judgment that State Farm’s failure to pay claims within thirty days of its receipt of written requests violated § 2118B(c). 6 As ballast for that contention, the Policyholders relied upon an answer that State Farm gave to an interrogatory that asked it to identify the number of PIP- claims on which State Farm had made any statutory interest payments since February 20, 2011. State Farm replied that it made interest payments on 6,349 such claims during that period of over three years. The interrogatory did not ask what percentage of PIP claims that amounted to over the three-year period.

According to the Policyholders, State Farm’s supposed regular. failure to pay claims within thirty days deprives the policyholders of the benefit of their bargain under their • insurance policies,, because part of the insurance contracts with State Farm is compliance with statutory coverage determinations and payment deadlines. Irrespective of whether State Farm eventually pays claims in full plus the required statutory interest, the Policyholders assert that § 2118B(c)’s remedy provision is a “penalty” and that State Farm should not be allowed to skirt the thirty-day requirement by opting to pay the alleged penalty. They seek a judicial judgment that “State Farm must pay or deny claims for Personal Injury Protection coverage within 30 days of receipt of the claim.” 7

State Farm contested the motion for leave to amend, arguing that the Policyholders lacked standing because they did not plead any injury, and because the claim for declaratory relief was not ripe.

2. The Superior Court Denies The Policyholders’ Motion For Leave To Amend And Grants State Farm’s Motion For Summary Judgment

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Bluebook (online)
131 A.3d 806, 2016 Del. LEXIS 10, 2016 WL 125432, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clark-v-state-farm-mutual-automobile-insurance-del-2016.