Dillashaw v. GEICO General Insurance Company

CourtDistrict Court, M.D. Florida
DecidedMay 16, 2022
Docket8:21-cv-02333
StatusUnknown

This text of Dillashaw v. GEICO General Insurance Company (Dillashaw v. GEICO General Insurance Company) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dillashaw v. GEICO General Insurance Company, (M.D. Fla. 2022).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

DIANE DILLASHAW,

Plaintiff,

v. Case No: 8:21-cv-2333-CEH-JSS

GEICO GENERAL INSURANCE COMPANY,

Defendant. ___________________________________/ ORDER This cause comes before the Court upon Plaintiff Diane Dillashaw’s Motion to Remand (Doc. 11), which Defendant GEICO General Insurance Company opposes (Doc. 14). Diane Dillashaw sues GEICO General Insurance Company for bad faith under Florida law. Seeking to invoke the Court’s subject-matter jurisdiction on the basis of diversity jurisdiction, GEICO removed the action. Dillashaw now moves for remand, arguing that the Court must return this bad-faith action to state court because GEICO has failed to establish that the amount in controversy exceeds $75,000, exclusive of interest and costs. The Court agrees. Therefore, as explained in more detail below, the Court will grant the Motion to Remand. I. BACKGROUND On or about February 5, 2018, Diane Dillashaw allegedly drove north on North Falkenburg Road in Tampa, Florida. Doc. 1-1 at 2. Kenneth Allan Jones also drove north on that road, two vehicles behind Dillashaw’s vehicle. Id. Kenneth Len Jones owned the vehicle that Kenneth Allan Jones operated. Id. According to Dillashaw, GEICO General Insurance Company insured both Kenneth Allan Jones and Kenneth

Len Jones under an automobile insurance policy. Id. Dillashaw alleges that, when she slowed down, and stopped, her vehicle to yield to traffic, Kenneth Allan Jones’s vehicle struck the vehicle ahead of his vehicle, causing that vehicle to strike her vehicle. Id. Dillashaw allegedly sustained injuries. Id.

Dillashaw sued Kenneth Allan Jones and Kenneth Len Jones in state court. See id. at 3; Doc. 1-6 at 1–2; Doc. 10-1 at 68. On March 19, 2021, based upon the consent of the parties in that action, the state court entered a $110,000 judgment in favor of Dillashaw and against Kenneth Allan Jones and Kenneth Len Jones, jointly and severally. Doc. 1-6 at 1–2; Doc. 10-1 at 68–69.

On or about May 19, 2021, Dillashaw filed a civil remedy notice of insurer violations, commonly known as a “CRN,” against GEICO. Doc. 1-1 at 65. In the CRN, Dillashaw asserted that GEICO violated Florida Statutes §§ 624.155(1)(b)(1), 626.9541(1)(i)(3)(e). Id.1

1 “Any person may bring a civil action against an insurer when such person is damaged . . . by the commission of any of the following acts by the insurer . . . [n]ot attempting in good faith to settle claims when, under all the circumstances, it could and should have done so, had it acted fairly and honestly toward its insured and with due regard for her or his interests . . . . Fla. Stat. § 624.155(1)(b)(1). A person may also bring a civil action against an insurer when that person is damaged by the insurer’s failure “to affirm or deny full or partial coverage of claims, and, as to partial coverage, the dollar amount or extent of coverage, or fail[ure] to provide a written statement that the claim is being investigated, upon the written request of the insured within 30 days after proof-of-loss statements have been completed.” Fla Stat. §§ 624.155(1)(a)(1), 626.9541(1)(i)(3)(e) Dillashaw then initiated this action against GEICO in state court (Doc. 1-1). She brings one bad-faith claim against GEICO. Doc. 1-1 at 2. She alleges that GEICO breached its continuing duties under Florida Statutes § 624.155 by not attempting to

settle her claims when, under the circumstances, it could and should have done so, if it had acted fairly and honestly towards its insured and with due regard for her interests. Id. at 3. Dillashaw alleges that GEICO breached its duty of good faith through other acts or omissions, including improperly handling the claim and refusing to settle the claim in a timely manner. Id.

According to Dillashaw, as a direct and proximate cause of GEICO’s bad faith, she obtained the $110,000 judgment against Kenneth Allan Jones and Kenneth Len Jones, “which has not been satisfied to date,” even after Dillashaw’s “subsequent demand.” Id. at 4. She also alleges that GEICO’s bad faith caused her damages, such

as “mental pain and suffering, emotional distress, humiliation, anguish, loss of enjoyment of life, economic losses, [and] costs and attorney’s fees.” Id. She asserts that she now “seeks to recover her judgement [sic] award and her attorney’s fees” against GEICO. Id. GEICO removed the action on the basis of diversity jurisdiction. Doc. 1 at 7–9.

Relevant here, GEICO asserted that the amount in controversy exceeded $75,000, exclusive of interest and costs, because Dillashaw alleges that she seeks to recover payment of the $110,000 consent judgment. Id. at 9. Dillashaw now seeks remand (Doc. 11), which GEICO opposes (Doc. 14). II. LEGAL STANDARD A defendant may remove a civil action from state court to the district court of

the United States for the district and division within which the action pends, as long as the district court has jurisdiction. 28 U.S.C. § 1441(a). District courts have original jurisdiction over actions between citizens of different states where the amount in controversy exceeds $75,000, exclusive of interest and costs. 28 U.S.C. § 1332(a). “The burden of establishing subject matter jurisdiction falls on the party invoking removal.”

Univ. of S. Ala. v. Am. Tobacco Co., 168 F.3d 405, 411–12 (11th Cir. 1999). Courts measure the amount in controversy at the time of removal. Pretka v. Kolter City Plaza II, 608 F.3d 744, 751 (11th Cir. 2010). When a plaintiff’s state-court complaint offers an unspecified demand for damages, a removing defendant must prove, by a preponderance of the evidence, that the amount in controversy more likely

than not exceeds the jurisdictional requirement. Roe v. Michelin N. Am., Inc. 613 F.3d 1058, 1061 (11th Cir. 2010). But, in some cases, “it may be ‘facially apparent’ from the pleading itself that the amount in controversy exceeds the jurisdictional minimum,” even when the state-court complaint does not claim a specific amount of damages. Id. (internal quotation marks omitted). If a defendant contends that removability is

apparent from the face of the complaint, the district court must analyze whether the complaint itself satisfies the defendant’s jurisdictional burden. Id. “[W]ithout facts or specific allegations,” divining the amount in controversy only through speculation is “impermissible.” Pretka, 608 F.3d at 763–54 (internal quotation marks omitted). But district courts may “make reasonable deductions, reasonable inferences, or other reasonable extrapolations from the pleadings to determine whether it is facially apparent that a case is removable.” Roe, 613 F.3d at 1061–62 (internal quotation marks omitted); see Pretka, 608 F.3d at 754 (stating that a

removing defendant who offers “specific factual allegations establishing jurisdiction (if challenged by the plaintiff or the court) with evidence combined with reasonable deductions, reasonable inferences, or other reasonable extrapolations” does not engage in “conjecture, speculation, or star gazing”). Thus, “courts may use their judicial experience and common sense in determining whether the case stated in a

complaint meets federal jurisdictional requirements.” Roe, 613 F.3d at 1062. III.

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Dillashaw v. GEICO General Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dillashaw-v-geico-general-insurance-company-flmd-2022.