Coultas v. Liberty Mutual Fire Insurance

32 Mass. L. Rptr. 12
CourtMassachusetts Superior Court
DecidedAugust 15, 2013
DocketNo. SUCV201300311
StatusPublished

This text of 32 Mass. L. Rptr. 12 (Coultas v. Liberty Mutual Fire Insurance) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coultas v. Liberty Mutual Fire Insurance, 32 Mass. L. Rptr. 12 (Mass. Ct. App. 2013).

Opinion

Leibensperger, Edward P., J.

This action arises from the conduct of Liberty Mutual Fire Insurance Company (“Liberty”) as a workers’ compensation insurer. In the course of that conduct, Liberty took the position that it had obtained assignments from plaintiffs to commence lawsuits against third parties for injuries plaintiffs suffered as a result of a work-related accident. Based on the purported assignments, Liberty commenced lawsuits against three third parties. After learning of the third-party actions, plaintiffs objected to Liberty’s prosecution of the actions. A substantial amount of litigation, including administrative proceedings, ensued between plaintiffs and Liberty before it was finally determined that Liberty had not, in fact, received valid assignments of plaintiffs’ causes of action. Plaintiffs commenced this action alleging that Liberty, as a workers’ compensation insurer, breached its contract with them, as third-party beneficiaries of the insurance contract, by violating applicable Oregon law governing workers’ compensation. Plaintiffs also allege that Liberty engaged in fraud, deceit, civil conspiracy and violations of G.L.c. 93A in its dealings with them. Liberty now moves to dismiss contending that plaintiffs’ claims are based solely on Liberty’s commencement of the third-party actions. Because the commencement of such third-party actions was an exercise of Liberty’s right of petition, Liberty contends that this action should be dismissed pursuant to G.L.c. 231, §59H, popularly known as the “anti-SLAPP” (Strategic Lawsuit Against Public Participation) statute. For the reasons described below, Liberty’s motion will be denied.

BACKGROUND

On August 5, 2008, a helicopter crashed in the mountains of Northern California during a firefighting mission. In the crash, Roark Schwanenberg, the pilot, was killed. His wife, plaintiff, Christine Schwanenberg, is the personal representative of his estate. Also, plaintiff, William H. Coultas, the co-pilot of the helicopter, was severely injured. The crash resulted in eight other deaths and injuries to three additional persons.

At the time of the crash, Mr. Schwanenberg and Mr. Coultas were employed by Carson Helicopters, Inc., a company located in Oregon. Carson had entered into a contract with Liberty to provide workers’ compensation insurance to Carson for its employees. The workers’ compensation insurance was provided pursuant to the Oregon Workers’ Compensation Law. Plaintiffs allege that they are third-party beneficiaries of the contract between Liberty and Carson for workers’ compensation benefits.

As a result of the crash, Liberty paid workers’ compensation benefits to plaintiffs. Death benefits were paid Mrs. Schwanenberg. With respect to Mr. Coultas, benefits were paid directly to him. The payment of benefits by Liberty commenced the direct relationship between Liberty and plaintiffs, as insurer and insureds, under the Oregon statute.

According to plaintiffs, the relationship with Liberty was oppressive from the outset. For example, Mr. Coultas affirms that “before, during and after” the receipt from Liberty of a letter dated October 7, 2008— a key document that will be described in the next paragraph — a Liberty agent was in constant contact with him. Liberty allegedly required Mr. Coultas to have an insurance adjustor attend his medical visits including ones that involved intimate examination of his serious wounds. Mr. Coultas alleges that Liberty, through its agent, knew of the debilitated physical, emotional and psychological state he was in at the time they sent the October 7, 2008 letter, only two months after the crash. Similarly, Mrs. Schwanenberg alleges that she suffered depression and post-traumatic stress arising from her grief upon the tragic loss of her husband. As a result, her ability to make important decisions was still impaired when, only two months after the crash, Liberty sent her the letter dated October 7, 2008 that was essentially the same as the letter sent to Mr. Coultas.

[13]*13The two letters dated October 7, 2008, hereinafter referred to as the “Letters” or the “Letter,” constituted demands by Liberty that plaintiffs make an election, withing sixty (60) days of receipt of the Letters, whether to bring suit against “a third party” potentially responsible for the crash or to assign that right to Liberty. The Letters did not identify by name any third party or parties.

Oregon Revised Statutes (“ORS”) provide that an insurer “may” compel such an election and prompt action. ORS 656.583. To do so, the insurer must serve the worker with a written demand. ORS 656.583(1). Unless such an election is made within 60 days from receipt or service of such a demand and unless, after making such election, an action against a third party is instituted within such time as is granted by the insurer, the worker is deemed to have assigned the cause of action to the insurer. ORS 656.583(2). The insurer must allow the worker at least 90 days from the making of an election to institute his own action to institute that action. Failure to proceed against the third party operates as an1 assignment to the insurer of the cause of action, if any, of the worker against the third parly. ORS 656.591.

Liberty decided to initiate the ORS 656.583(1) demand within two months of the crash. It sent the October 7, 2008 Letters by certified mail, return receipt requested. The Letters explained that Liberty’s review of the case indicated that “your injuries may have been caused by the negligence of a third party.” The Letters then explained that under Oregon law, a worker “may be entitled to bring suit against that third party and recover civil damages. Alternatively, you may decide not to pursue that party yourself and assign your right to us.”

The Letters then demanded that Mr. Coultas and Mrs. Schwanenberg “at this time” make a choice. CHOICE A was to indicate by return mail that he/she intended to seek damages against a third party himself or herself. CHOICE B was to indicate that he/she did not intend to seek damages “from the third party” (again, no third party was identified). The Letters stated that if they elected CHOICE B, their rights would be assigned to Liberty to pursue the third party. Liberty advised “[i]f you fail to respond in that time [60 days from receipt of the Letter], your right to pursue the third party will automatically be assigned to us without further option on our part.” If they elected CHOICE A, the Letter said nothing about how long Liberty would allow Mr. Coultas and Mrs. Schwanenberg to institute their own actions.

Mrs. Schwanenberg received the Letter on October 14, 2008. Mr. Coultas received the Letter on October 16, 2008. Mrs. Schwanenberg swears that she placed a checkmark next to CHOICE A and gave the Letter to a family friend to mail to Liberty. Mr. Coultas placed a checkmark next to CHOICE A and mailed the Letter to Liberty. Liberty received Mr. Coultas’s letter, but claims it did not receive Mrs. Schwanenberg’s letter. Liberty, however, never contacted Mrs. Schwanenberg to see if she returned the letter or to ask what her choice was.

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Cite This Page — Counsel Stack

Bluebook (online)
32 Mass. L. Rptr. 12, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coultas-v-liberty-mutual-fire-insurance-masssuperct-2013.