Combs v. Nationwide Insurance Company of America

CourtDistrict Court, W.D. Washington
DecidedOctober 5, 2023
Docket3:22-cv-05684
StatusUnknown

This text of Combs v. Nationwide Insurance Company of America (Combs v. Nationwide Insurance Company of America) 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
Combs v. Nationwide Insurance Company of America, (W.D. Wash. 2023).

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 PHILLIP P COMBS; JAMIE COMBS, Case No. 3:22-cv-05684-TMC 8 Plaintiff, ORDER DENYING DEFENDANT’S 9 MOTION TO EXCLUDE v. 10 NATIONWIDE INSURANCE COMPANY 11 OF AMERICA, Defendant. 12 13

14 Before the Court is Defendant Nationwide Insurance Company of America’s 15 (“Nationwide’s”) motion to exclude evidence. Dkt. 15. For the reasons explained below, the 16 Court DENIES Nationwide’s motion. 17 I. BACKGROUND 18 In July 2020, a storm damaged the roof of a home in Lakewood, Washington owned by 19 Plaintiffs Phillip and Jamie Combs.1 Dkt. 1-2 at 2. The Combses submitted a claim under a 20 homeowners’ insurance policy issued by Nationwide. Id. They filed this case in Pierce County 21 Superior Court in August 2022, alleging Nationwide breached the insurance policy and acted in 22 23 1 To avoid confusion, where necessary the Court will refer to Phillip and Jamie Combs by their 24 first names. 1 bad faith while processing their claim. Dkt. 1-2 at 3–10. Nationwide removed the case to this 2 Court based on diversity jurisdiction. Dkt. 1 at 2; 28 U.S.C. §§ 1332(a), 1441. 3 On November 14, 2022, the Combses served Nationwide with their initial disclosures

4 required by Federal Rule of Civil Procedure 26(a)(1)(A). The “computation of damages” section 5 listed only categories of damages, rather than amounts, but said the Combses would supplement. 6 Dkt. 16-1 at 3. The description of two categories (fire loss and rental income) later proved to be 7 incorrect. A few weeks later, on December 6, 2022, the Combses supplemented their disclosures, 8 removing the incorrect categories and writing: “Thus far . . . compensatory damages in the 9 amount of $119,100.00 are known.” Dkt. 16-3. The disclosure referenced two repair estimates 10 from Sam’s Roofing with amounts of $98,000 and $21,100 (which add up to the compensatory 11 damages estimate of $119,100). Id. On February 1, 2023 the Combses provided interrogatory 12 answers describing temporary repairs they had performed to the house, including that “last 13 summer, Plaintiff hired a roofer to replace portions of the damaged roof . . . .” Dkt. 16-4 at 3.

14 They produced a quote from Wilderness Roofing & Exteriors, LLC that showed a total amount 15 of $77,330.00 and was signed with Phillip’s initials, “PC.” Id. at 5; Dkt. 18-1. 16 In Jamie’s deposition on July 18, 2023, she testified she could not recall the “exact 17 number” for replacing the roof but “want[ed] to say $75,000.” Dkt. 16-6 at 4. Jamie testified that 18 she and her husband would provide any invoices they had for the repair. Id. at 5. Jamie and 19 Phillip both confirmed that two categories of damages listed in the November 2022 initial 20 disclosures, fire loss and rental income, were incorrect. Id. at 7; 16-7 at 4. In Phillip’s deposition 21 on July 20, 2023, when questioned about the quote from Wilderness Roofing and whether there 22 had been a final invoice, Phillip testified: “I don’t know that we’ve even received an invoice. I

23 think we may have paid off from the quote, but if – I’ll – I’ll look back, and if we have it, I’ll 24 provide it.” Dkt. 16-7 at 9. 1 At no point did Nationwide file a motion to compel. Instead, on August 8, 2023, with 2 over a month remaining in discovery, Nationwide filed this motion seeking to prohibit the 3 Combses from producing any further evidence to support their damages computation as a

4 discovery sanction under Federal Rule of Civil Procedure 37. Dkt. 15. 5 The discovery cutoff when Nationwide filed its motion was September 15, 2023. At both 6 parties’ request, the Court later extended the cutoff to September 29, 2023. Dkts. 24, 25. The 7 Court also allowed the parties to schedule an additional deposition for after the discovery cutoff. 8 Dkt. 27. 9 II. DISCUSSION A. Legal Standard 10 Federal Rule of Civil Procedure 26(a)(1)(A)(iii) requires a party to provide “a 11 computation of each category of damages claimed by the disclosing party—who must also make 12 available for inspection and copying ... the documents or other evidentiary material, unless 13 privileged or protected from disclosure, on which each computation is based, including materials 14 bearing on the nature and extent of injuries suffered.” Fed. R. Civ. P. 26(a)(1)(A)(iii). The rule 15 does not clarify the level of specificity required in the computation of damages. According to the 16 advisory committee notes, the purpose of the rule is to “‘accelerate the exchange of basic 17 information’ that is ‘needed in most cases to prepare for trial or make an informed decision about 18 settlement.’” City and County of San Francisco v. Tutor-Saliba Corp., 218 F.R.D. 219, 221 19 (N.D. Cal. 2003) (quoting Fed. R. Civ. P. 26(a) advisory committee’s note (1993)). “[E]arly 20 disclosure also functions to assist the parties in focusing and prioritizing their organization of 21 discovery.” Id. “Given these purposes, the plaintiff should provide more than a lump sum 22 statement of the damages allegedly sustained.” Id. The computation of damages “contemplates 23 24 1 some analysis; for instance, in a claim for lost wages, there should be some information relating 2 to hours worked and pay rate.” Id. (citing cases). 3 Rule 37 provides that “[i]f a party fails to provide information or identify a witness as

4 required by Rule 26(a) or (e), the party is not allowed to use that information or witness to 5 supply evidence on a motion, at a hearing, or at a trial, unless the failure was substantially 6 justified or is harmless.” Fed. R. Civ. P. 37(c)(1). “Under Rule 37, exclusion of evidence not 7 disclosed is appropriate unless the failure to disclose was substantially justified or harmless.” 8 Hoffman v. Construction Protective Servs., Inc., 541 F.3d 1175, 1179 (9th Cir. 2008) (citing Yeti 9 by Molly, Ltd. v. Deckers Outdoor Corp., 259 F.3d 1101, 1106 (9th Cir. 2001)). 10 B. The Combses’ supplemental disclosures complied with Rule 26 and any delay was harmless. 11 The Court agrees with Nationwide that the Combses’ November 2022 initial 12 disclosures—which provided only categories of damages, with no amount or method of 13 computation, two of which were in error—did not comply with Rule 26. But within a few weeks, 14 the Combses supplemented their disclosures, withdrew the incorrect categories, estimated 15 compensatory damages of $119,100.00, and referenced two simple one-page repair estimates 16 adding up to that amount. Dkt. 16-3; compare Weinstein & Riley, PS v. Westport Ins. Co., No. C- 17 08-1694-JLR, 2009 WL 10676389, at *2 (W.D. Wash. Nov. 4, 2009) (finding party failed to 18 comply with Rule 26 where it simply referenced the entire voluminous litigation file). A few 19 months later, the Combses provided another quote from the roofer whom they had paid out of 20 pocket, Dkt. 18-1, and in their depositions, they testified that the amount they paid was 21 consistent with that quote and pledged to produce any additional documentation they could find, 22 Dkt. 16-6, 16-7.

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Related

Hoffman v. Construction Protective Services, Inc.
541 F.3d 1175 (Ninth Circuit, 2008)
Yeti by Molly Ltd. v. Deckers Outdoor Corp.
259 F.3d 1101 (Ninth Circuit, 2001)
City & County of San Francisco v. Tutor-Saliba Corp.
218 F.R.D. 219 (N.D. California, 2003)

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Combs v. Nationwide Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/combs-v-nationwide-insurance-company-of-america-wawd-2023.