Coleman v. United Services Automobile Association

CourtDistrict Court, S.D. California
DecidedJanuary 9, 2025
Docket3:21-cv-00217
StatusUnknown

This text of Coleman v. United Services Automobile Association (Coleman v. United Services Automobile Association) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coleman v. United Services Automobile Association, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 EILEEN-GAYLE COLEMAN, et al., Case No.: 21-cv-217-RSH-KSC

12 Plaintiffs, ORDER ADDRESSING PENDING 13 v. MOTIONS

14 UNITED SERVICES AUTOMOBILE [ECF Nos. 167, 169, 173, 174, 179, 181, ASSOCIATION, et al., 15 189] Defendants. 16 17 18 Pending before this Court are, among other motions, (1) a motion for summary 19 judgment filed by defendants United Services Automobile Association (“United Services”) 20 and USAA General Indemnity Co. (“GIC”) [ECF No. 173] and (2) a motion for partial 21 summary judgment filed by class representatives Eileen-Gayle Coleman and Robert Castro 22 [ECF No. 169]. 23 United Services Automobile Association (“USAA”) offers insurance to members of 24 the military and their families through its subsidiaries, including United Services and GIC. 25 USAA has placement rules under which commissioned officers and higher-ranking 26 enlisted personnel are assigned to United Services, and other enlisted personnel are 27 assigned to GIC. Based on historic losses among the respective pools of policyholders, the 28 1 California Department of Insurance has approved rates that are lower for United Services 2 and higher for GIC. 3 California Insurance Code section 1861.16(b) provides that, where insurers have 4 common ownership, they must offer to statutory “good drivers” a discount policy from 5 whichever insurer within that common ownership offers the lowest rates, “notwithstanding 6 the underwriting guidelines of any of those insurers.” Roughly 70% of GIC’s insureds— 7 approximately two million individuals—are statutory good drivers. Plaintiffs contend that, 8 despite USAA’s placement rules, and despite the fact that the Department approved rates 9 for each company based on historic losses of their policyholders, Section 1861.16(b) 10 requires USAA to assign those individuals to United Services rather than GIC and to charge 11 them the lower United Services rates. 12 Another provision of the California Insurance Code, section 11628(f)(1), provides 13 that nothing in the code “shall prohibit an insurer from limiting the issuance or renewal of 14 insurance … to persons who engage in … governmental or military service or segments of 15 categories thereof,” and their families. Defendants contend that under this statute, United 16 Services may limit its issuance of insurance to “segments” of servicemembers, as set forth 17 in USAA’s placement rules, even where the would-be insured is a statutory good driver. 18 This case presents a legal question of first impression: Whether Section 1861.16(b) 19 requires USAA to assign all statutory good drivers to the USAA subsidiary with the lower 20 rate, or whether Section 11628(f)(1) protects USAA’s ability to assign insureds, including 21 good drivers, in accordance with its placement rules.1 The Court concludes that under the 22 clear language of the relevant statutes, the Insurance Code does not compel USAA to 23 ignore its placement rules that limit insurance “to persons who engage in … governmental 24 25 26 1 This legal question may not, in practical terms, have any present application beyond 27 the USAA group of insurance companies. At oral argument, neither party was aware of any auto insurance company doing business in California with placement rules that assign 28 1 or military service or segments of categories thereof.” Based on this conclusion, 2 Defendants are entitled to summary judgment. 3 As set forth below, the Court grants Defendants’ motion for summary judgment, and 4 denies Plaintiffs’ motion for partial summary judgment. 5 I. BACKGROUND 6 A. Undisputed Facts 7 Defendant USAA is a reciprocal interinsurance exchange composed of affiliated 8 insurance companies. ECF No. 192 (Joint Statement of Undisputed Facts) at 2. Four 9 affiliated companies in the USAA corporate family provide auto insurance to different 10 segments of the military or their family members, including defendants United Services 11 and GIC. Id. Plaintiffs formerly served as enlisted military personnel with a highest pay 12 grade below E-6, and had (or still have) auto insurance through GIC for vehicles garaged 13 in California. Id. 14 The eligibility rules for each USAA company are mutually exclusive; military 15 members and their families are eligible to purchase policies from only one of the USAA 16 entities. Id. at 3. USAA describes the specific eligibility criteria for the four companies in 17 its placement rules, which have been revised periodically over the years. Id. As relevant 18 here, the placement rules dictate that United Services insures, among other categories of 19 policyholders, “[c]ommissioned and warrant officers in the U.S. Armed Forces [and] 20 [s]enior non-commissioned/petty officers, defined as E-7 or above in the U.S. Armed 21 Forces … on active duty … or retired from active duty … or separated with a discharge 22 type of ‘Honorable’ from active duty.” The placement rules also dictate that GIC insures, 23 with one other category of policyholders, “[e]nlisted and junior non-commissioned 24 officers, defined as E-1 through E-6 in the U.S. Armed Forces … on active duty … or 25 retired from active duty … or separated with a discharge type of ‘Honorable’ from active 26 27 28 1 duty.” Id. United Services and GIC operate under common management and control. Id. 2 at 2. 3 Since 1989, insurance companies in California—including the four USAA affiliates 4 depending on when they began operations in the State—have had to secure prior approval 5 from the California Department of Insurance (the “Department”) for the rates that are used 6 to set the premiums they charge policyholders. Id. at 3. The Department’s prior-approval 7 rate-setting process is regulated and data-driven. Id. The process is designed to ensure that 8 the ultimate rate filed with the Department is not excessive, inadequate or unfairly 9 discriminatory. Automobile “insurance rates … must be approved by the commissioner 10 prior to their use.” Cal. Ins. Code § 1861.01(c). The Department’s rate-setting process 11 requires that each insurer set its rates based partly on the amounts it has historically paid 12 out to its policyholders to settle claims. ECF No. 192 at 4. Historical losses are used to 13 project future losses. Id. 14 USAA has submitted rate applications that contain separate base rates for each of its 15 four insurance companies, including United Services and GIC. Id. at 5. The average GIC 16 policyholder has a history of greater losses than the average United Services policyholder, 17 and the Department has approved USAA’s applications for higher base rates for GIC than 18 for United Services at all relevant times. Id. at 6. The discrepancy in premiums paid by 19 United Services’ and GIC’s insureds is a result of each group’s corresponding history of 20 losses, and the role those historical losses play in setting each company’s base rates. Id. 21 If an insured meets the statutory good driver qualifications pursuant to California 22 Insurance Code section 1861.025, the insured receives at least 20 percent below the rate 23 the insured would otherwise have been charged for the same coverage. Id. at 5. At all 24 25 26 2 Plaintiffs have adopted the shorthand of referring to GIC’s policyholders as “enlisted 27 personnel” rather than as “current or former personnel whose highest paygrade was E-6 or below,” and referring to United Services’ policyholders simply as “officers.” ECF No. 182 28 1 relevant times, both GIC and United Services have applied a 20% discount on the total 2 premium amount for insureds who qualify as statutory good drivers. Id.

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Bluebook (online)
Coleman v. United Services Automobile Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coleman-v-united-services-automobile-association-casd-2025.