Deanna Rudd v. State Farm Fire and Casualty Company

CourtCourt of Appeals of Mississippi
DecidedMay 5, 2020
DocketNO. 2018-CA-01390-COA
StatusPublished

This text of Deanna Rudd v. State Farm Fire and Casualty Company (Deanna Rudd v. State Farm Fire and Casualty Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Deanna Rudd v. State Farm Fire and Casualty Company, (Mich. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2018-CA-01390-COA

DEANNA RUDD APPELLANT

v.

STATE FARM FIRE AND CASUALTY APPELLEE COMPANY

DATE OF JUDGMENT: 09/11/2018 TRIAL JUDGE: HON. ROBERT P. KREBS COURT FROM WHICH APPEALED: JACKSON COUNTY CIRCUIT COURT ATTORNEYS FOR APPELLANT: DOUGLAS LAMONT TYNES JR. COURTNEY PARKER WILSON ATTORNEYS FOR APPELLEE: H. BENJAMIN MULLEN MICHAEL RILEY MOORE NATURE OF THE CASE: CIVIL - INSURANCE DISPOSITION: AFFIRMED - 05/05/2020 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE J. WILSON, P.J., GREENLEE AND LAWRENCE, JJ.

LAWRENCE, J., FOR THE COURT:

¶1. Following a car accident, Deanna Rudd filed suit against her insurance company, State

Farm Fire and Casualty Company (State Farm), claiming that she was entitled to

underinsured motorist (UIM) benefits. Rudd also asserted claims for breach of fiduciary

duty, negligence/gross negligence in claim handling, and bad faith. She sought extra-

contractual and punitive damages. State Farm filed a motion for partial summary judgment

on the issues of bad faith and extra contractual and punitive damages. The Jackson County

Circuit Court granted State Farm’s motion, and Rudd appealed. Finding no genuine issues

of material fact, we affirm the circuit court’s judgment. FACTS

¶2. On July 27, 2010, Rudd was driving southbound in the left lane on Market Street in

Pascagoula, Mississippi.1 At the same time, Chrisma Houston was also driving southbound

in the right lane on Market Street.2 Houston merged left and struck Rudd’s vehicle. Both

vehicles were traveling between twenty-five and thirty miles per hour. An ambulance arrived

shortly after the collision. During her initial emergency-medical-technician (EMT)

interview, Rudd said she injured her back, neck, and left hip in the accident.

¶3. At the time of the accident, Houston was insured through Allstate and had $25,000

in liability coverage. Rudd was insured through State Farm and had $100,000 of

uninsured/underinsured motorist coverage and $10,000 in medical pay coverage (Med Pay).

State Farm’s records shows that, about a month before the accident, Rudd’s husband

requested that Rudd be removed from the policy because they were pursuing a divorce.

Rudd’s husband died on July 14, 2010, roughly two weeks before the accident. Based on

Rudd’s husband’s request to remove Rudd from the policy, State Farm initially determined

that coverage for Rudd was questionable. On July 30, 2010, Rudd spoke with a State Farm

agent and stated that she wanted to “handle everything” through Allstate—Houston’s

insurance carrier. On August 4, 2010, Rudd told a State Farm agent that she would contact

Allstate to determine whether a claim had been submitted.

1 Rudd had one passenger in her vehicle. 2 Houston had one passenger in her vehicle.

2 ¶4. On August 3, 2010, State Farm sent Rudd a letter detailing her Med Pay coverage,

which included reasonable and necessary medical expenses up to $10,000 per person. On

September 1, 2010, State Farm confirmed that Allstate accepted liability for the accident and

was handling damages owed to Rudd. By September 7, 2010, State Farm had collected

information that Rudd had made previous claims on other insurance policies for injuries she

suffered in falls, sudden impacts, and other car wrecks. The records spanned from 1992 to

2008 and included the following:

a. August 12, 1992—Rudd was in an automobile accident, suffering neck and right shoulder pain. Dr. John McCloskey treated her injuries.

b. April 8, 1994—Rudd was in an automobile accident, resulting in neck, left shoulder, and left jaw pain. She went physical therapy after that accident and was treated by Dr. McCloskey.

c. July 3, 1998—Rudd was in an automobile accident, resulting in neck pain. She was transported to the Singing River Hospital Emergency Room after the accident. She was primarily treated by Dr. McCloskey.

d. April 28, 2000—Rudd fell and injured her coccyx. She reported the injury to Dr. McCloskey.

e. August 8, 2001—Rudd was in an automobile accident, resulting in neck, back, and right shoulder pain. She was transported to the Singing River Hospital Emergency Room after the accident. She was primarily treated by Dr. McCloskey.

f. December 8, 2001—Rudd ran into a glass door at McRae’s. She complained to Dr. McCloskey of left shoulder and wrist pain.

g. 2008—Rudd was treated at Bienville Orthopedics for a possible fractured wrist.

h. May 24, 2008—Rudd was nearly hit by a bus at work, resulting in

3 injury to her back and neck. She was transported to the clinic at the Chevron Refinery before her husband took her to the emergency room in Mobile, Alabama. Dr. McCloskey treated her injuries.

State Farm obtained records showing that Rudd required significant medical treatment as a

result of these injuries, including physical therapy and pharmaceutical drugs. On September

28, 2010, State Farm confirmed to Allstate that it was paying up to $10,000 for Rudd’s Med

Pay coverage.

¶5. On December 17, 2010, State Farm determined that Rudd had exhausted her Med Pay

coverage. On July 28, 2011, State Farm sent Rudd’s husband3 a letter notifying him that

State Farm intended to pursue collection from the responsible parties. State Farm’s letter

also notified Rudd that any lawsuit must be brought within the statutory time period.

Between August 1, 2011, and August 15, 2012, State Farm continued handling Rudd’s claim

and communicating with Allstate. On November 5, 2012, State Farm agent Valarie Salter,

received a call from Allstate and learned that Rudd had at least $42,000.00 in medical bills.

On November 7, 2012, Allstate sent a letter asking State Farm to waive its subrogation

interest. On December 17, 2012, State Farm notified Allstate that it agreed to waive its

subrogation claim for payments made under the Med Pay portion of its policy.

¶6. On December 27, 2012, State Farm claim representative Ann McClendon reviewed

all of Rudd’s medical records to determine how much UM/UIM exposure was present. On

3 Rudd’s husband was deceased, but he was still listed as the policy holder. Because neither Rudd nor her husband lived at the address where they lived while married, the letter was returned as undeliverable.

4 January 11, 2013, Rudd called McClendon and left a voicemail stating that she was ready to

settle her bodily injury claim. A few days later, Rudd left a voicemail with another State

Farm representative, inquiring about the status of her claim. That representative informed

Rudd that McClendon was still evaluating her claim.

¶7. On January 31, 2013, McClendon sent Rudd a letter stating that State Farm had “re-

evaluated [her] claim, including the additional information provided, and determined the

value remains within the available limits of the responsible party.” As a result, State Farm

determined that Rudd was not entitled to payment under UM/UIM Coverage. McClendon

also reminded Rudd of the statute of limitations. According to State Farm’s records,

McClendon determined that Rudd was ineligible for UM/UIM coverage because of a seven-

month gap in her treatment, she was receiving disability benefits, and she was being treated

for pre-existing injuries at the time of the accident. McClendon also noted that, between

Allstate and State Farm, Rudd had received a total of $35,000. McClendon further

determined that this sum covered all of Rudd’s medical bills that were attributable to the July

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Deanna Rudd v. State Farm Fire and Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/deanna-rudd-v-state-farm-fire-and-casualty-company-missctapp-2020.