David Jackson v. Esurance Insurance Company

412 P.3d 299
CourtCourt of Appeals of Washington
DecidedDecember 11, 2017
Docket75506-4
StatusUnpublished
Cited by1 cases

This text of 412 P.3d 299 (David Jackson v. Esurance Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
David Jackson v. Esurance Insurance Company, 412 P.3d 299 (Wash. Ct. App. 2017).

Opinion

t ' 1 ST.nt E

2011DEC I I L

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DAVID JACKSON, ) No. 75506-4 -I ) Appellant, ) ) DIVISION ONE v. ) ) ESURANCE INSURANCE COMPANY, ) UNPUBLISHED OPINION ) Respondent. ) FILED: December 11,2017 ) MANN, J. —This case arises out of a single car accident during a training session at Pacific Raceways, a road and drag racing facility in Kent, Washington. Appellant

David Jackson asserted a claim for collision coverage under his personal auto policy

with Esurance Insurance Company (Esurance). Esurance denied coverage based on

an exclusion in the Esurance policy excluding collision coverage "for any vehicle located

inside a racing facility for the purpose of.. . or participating in any.. . driving school,

driver training,[or] skills training." Jackson sued Esurance for seeking coverage and

asserting claims for breach of contract, bad faith, and violations of the Consumer

Protection Act(CPA)and Insurance Fair Conduct Act(IFCA).

Jackson appeals from the trial court's decision granting summary judgment and

dismissing his claims. We affirm. No. 75506-4-1/2

FACTS

In February 2006, Jackson purchased a personal auto insurance policy with a

six-month term from Esurance. Esurance is an internet-based insurance company that

offers policyholders a paperless delivery system, whereby a policyholder can elect to

receive his or her policies, billings, and other documents through an online system

called "the online management platform." To participate in the platform, the policyholder

must affirmatively consent to receive documents electronically as opposed to through

U.S. Mail. The online management platform allows the policyholder to access and

review all prior policy documents that have been delivered at any time during the life of

the policy. A policyholder who consents to electronic delivery may request paper copies

of insurance policy documents at any time. The policyholder may also withdraw

consent; after doing so, the policyholder receives paper copies of the documents.

Jackson consented to receive his documents electronically via Esurance's paperless

delivery system when he purchased his initial policy. Jackson never withdrew his

consent or requested paper copies of documents.

Because Jackson's auto policy had a six-month term, Esurance renewed

Jackson's policy every six months by posting a "Renewal Offer" to the online

management platform and providing an e-mail notification to Jackson that the policy

was up for renewal and that he should review the terms and conditions. The e-mails

included a link to the online management platform. Esurance posts the renewal offers

at least 40 days before the effective date of the renewal policy. Each renewal offer

contains multiple documents: a renewal offer declarations page.listing all of the policy

forms that are part of the renewal policy being offered, and a copy of any new policy

-2- No. 75506-4-1/3

forms, amendments, or changes to policy terms. If there are no changes to the prior

policy's form, however, Esurance does not repost the prior policy form, but instead lists

the prior policy on the declarations page.1

Jackson's original February 2006 personal auto policy excluded losses that

occurred inside a racing facility when the car is driven to compete in or practice for any

race:

[Esurance] will not pay for:

13. Loss to "your covered auto" or any "non-owned auto", located inside a facility designed for racing, for the purpose of:

a. Competing in; or b. Practicing or preparing for any prearranged or organized racing or speed contest.

Jackson's Esurance policy renewed every six months and remained in effect from

February 2006 through February 2010.

In January 2010, Esurance provided Jackson an offer for the policy renewal

effective February 2010. The e-mail notification included the following statement:"By

renewing your policy, you're agreeing to Esurances's current Terms and Conditions."

The phrase Terms and Conditions was set out in blue and was a hyperlink to the terms

and conditions of the renewal. The renewal offer included a copy of the policy

declarations page, renewal offer, a notice of policy changes, and a complete copy of the

new personal auto policy form. The renewal offer, and all documents, were posted to

1 This is also Esurance's practice for delivering policy documents to policyholders who choose to receive physical paper copies of their insurance documents through the U.S. Mail. -3- No. 75506-4-1/4

Jackson's online management platform. The notice of policy changes included with the

renewal offer stated:

IMPORTANT NOTICE Explanation of Policy Changes

You Have Been Issued a New Automobile Policy

Enclosed in this renewal offer is your new Esurance Automobile Policy (Form 1000 WA 11 08), which has been approved by the Washington Department of Insurance. The new policy differs in many ways from your old policy. This Explanation of Policy Changes generally describes the changes. Your new policy contains all of the changes in full detail, so please read your new policy carefully.

The notice of policy change explained that Esurance had expanded the racing

exclusion:

We added language excluding coverage for any vehicle while competing in, or practicing or preparing for, any prearranged or organized racing or speed contest.

We added an exclusion for any vehicle located inside a racing facility for the purpose of competing in, practice or preparing for any prearranged or organized racing or speed contest, or participating in any racing school, driving school, driver training, skills training, race driving experience, or racing adventure program.

The new policy included with the new offer included a broader racing exclusion that

excluded losses caused when the car was driven for any race-skills instruction program:

[Esurance] will not provide coverage for:

12. "Loss" to any vehicle located inside a facility designed for racing or high performance driving for the purpose of:

A. Competing in; B. Practicing or preparing for; any prearranged or organized racing or speed contest; or

-4- No. 75506-4-1/5

C. Participating in any racing school, driving school, driver training, skills training, race driving experience, or racing adventure program.P]

Jackson accepted this policy by paying the first installment amount due on the policy.

Esurance sent Jackson a confirming e-mail thanking him for renewing his policy and

telling him he could review, save, or print his policy by logging into his account.

Jackson apparently never accessed the online portal and never read the policy.

Jackson's Esurance policy continued to renew every six months and remained in effect

from February 2010 through February 2013.

On January 6, 2013, Esurance provided Jackson another renewal offer that

included a new policy. This policy included the same racing exclusion as the February

2010 policy. Esurance posted the complete policy on Jackson's online management

platform. Jackson accepted this policy by paying the installment premium due. The

next three renewal offers (sent July 2013, January 2014, and July 2014) did not contain

a copy of the policy because Esurance did not change the policy.

In late June 2014, Jackson planned to attend an Audi driving-skills training

program offered at the Pacific Raceways racecourse. Before attending the event, he

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412 P.3d 299, Counsel Stack Legal Research, https://law.counselstack.com/opinion/david-jackson-v-esurance-insurance-company-washctapp-2017.