Daily Underwriters of America v. Veronica Williams

CourtCourt of Appeals of Georgia
DecidedMarch 13, 2020
DocketA19A2101
StatusPublished

This text of Daily Underwriters of America v. Veronica Williams (Daily Underwriters of America v. Veronica Williams) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daily Underwriters of America v. Veronica Williams, (Ga. Ct. App. 2020).

Opinion

FIFTH DIVISION MCFADDEN, C. J., MCMILLIAN, P. J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

March 13, 2020

In the Court of Appeals of Georgia A19A2101. DAILY UNDERWRITERS OF AMERICA v. WILLIAMS. A19A2102. DAILY UNDERWRITERS OF AMERICA v. WILLIAMS.

MCFADDEN, Chief Judge.

The issue in these companion appeals is whether Georgia law authorizes the

direct actions Veronica Williams and Marleaux Williams brought against the insurer

of an interstate motor carrier. One of Georgia’s direct action statutes, OCGA § 40-1-

112 (c), does not authorize those actions because it is applicable only to intrastate

motor carriers. But the other direct action statute, OCGA § 40-2-140 (d) (4), which

is applicable to interstate carriers, does authorize them. So we affirm the trial court’s

denials of the insurer’s summary judgment motions claiming that the direct actions

against it were not authorized. 1. Facts and procedural posture.

Viewed in the light most favorable to the nonmovants, see Aequicap Ins. Co.

v. Canal Ins. Co., 303 Ga. App. 508, 508 (693 SE2d 863) (2010), the evidence shows

that on July 18, 2014, Veronica and Marleaux Williams were injured when a tractor-

trailer driven by Edward Heard struck their car. Heard owns and operates CC&D

Trucking, LLC as a sole proprietorship, and he was driving in the scope of the

business of CC&D at the time of the accident. Daily Underwriters of America had

issued a liability insurance policy to CC&D which was in effect at the time of the

accident.

Veronica Williams, the car driver, and Marleaux Williams, the car passenger,

brought separate negligence actions against Heard, CC&D, and Daily Underwriters.

They cited OCGA § 40-1-112 (c) in their complaints as authorizing those direct

actions against Daily Underwriters.

Daily Underwriters moved for summary judgment in each case, arguing that

OCGA § 40-1-112 (c) applies only to insurers of intrastate motor carriers. Daily

Underwriters contended that its insured, CC&D, was an interstate motor carrier at the

time of the crash. Therefore it argued, OCGA § 40-1-112 (c) does not authorize the

direct actions against Daily Underwriters.

2 In their response, the Williamses cited, among other things, OCGA § 40-2-140

as authorizing the direct actions against the insurer. The trial court denied Daily

Underwriters’ motions for summary judgment.

We granted Daily Underwriters’ applications for interlocutory review, and

these appeals followed. In Case No. A19A2101, Daily Underwriters appeals from the

trial court’s denial of its motion for summary judgment in the action filed by Veronica

Williams. In Case No. A19A2102, it appeals from the denial of its corresponding

motion in the suit filed by Marleaux Williams. Because the appeals raise the same

issues, we consider them together.

2. Direct action statutes.

Daily Underwriters argues that direct actions against the insurer of an interstate

motor carrier are not authorized in Georgia. It is true that the general rule in Georgia

is that a liability insurer may not be joined directly as a defendant in an action for

damages against its insured. Haezebrouck v. State Farm Mut. Ins. Co., 252 Ga. App.

248, 249 (1) (555 SE2d 764) (2001). But exceptions for motor carriers to that general

rule are provided by two separate direct action statutes: OCGA §§ 40-1-112 (c) and

40-2-140 (d) (4). See Frank E. Jenkins III & Wallace Miller III, Ga. Automobile

Insurance Law § 46:1 (b) (1) (2019-2020 ed.).

3 As explained below, OCGA § 40-1-112 (c), when read together with OCGA

§ 40-1-126, authorizes direct actions against insurers of motor carriers engaged in

intrastate commerce — but not against insurers of motor carriers engaged in purely

interstate commerce. OCGA § 40-2-140 (d) (4), however, does authorize direct

actions against insurers of motor carriers engaged in interstate commerce.

(a) OCGA § 40-1-112 (c).

(i) The statute construed.

OCGA § 40-1-112 is found in the Georgia Motor Carrier Act of 2012. See

OCGA §§ 40-1-50 through 40-1-200. OCGA § 40-1-112 (a) requires a “motor carrier

of household goods or property or passengers” to file with the Department of Public

Safety a certificate of insurance “evidencing a policy of indemnity insurance by an

insurance company licensed to do business in this state . . . . The failure to file any

form required by the department shall not diminish the rights of any person to pursue

an action directly against a motor carrier’s insurer.” (Emphasis supplied.) The right

to pursue such a direct action against an insurer is set out in OCGA § 40-1-112 (c),

which provides: “It shall be permissible under this part [i.e., Title 40, Chapter 1,

Article 3, Part 2] for any person having a cause of action arising under this part to join

4 in the same action the motor carrier and the insurance carrier, whether arising in

tort or contract.” (Emphasis supplied.) As this court has explained,

[t]he purpose of permitting joinder of the insurance company in a claim against a common carrier is to further the policy of the Motor Carrier Act, that is, to protect the public against injuries caused by the motor carrier’s negligence. The intent of this [s]tate’s motor carrier laws is that the insurer is to stand in the shoes of the motor carrier and be liable in any instance of negligence where the motor carrier is liable.

Mornay v. Nat. Union Fire Ins. Co. of Pittsburgh, 331 Ga. App. 112, 113 (769 SE2d

807) (2015) (citation and punctuation omitted).

Within the same part of the Georgia Motor Carrier Act is a disavowal of any

apparent effort by the state to regulate purely interstate commerce. OCGA § 40-1-126

provides:

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Bluebook (online)
Daily Underwriters of America v. Veronica Williams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daily-underwriters-of-america-v-veronica-williams-gactapp-2020.