Dusty L. Dye and Rebecca H. Dye v. Allstate Vehicle and Property Insurance Company and Jimmy Willis Insurance Services, LLC

CourtDistrict Court, N.D. Oklahoma
DecidedJune 24, 2026
Docket4:26-cv-00001
StatusUnknown

This text of Dusty L. Dye and Rebecca H. Dye v. Allstate Vehicle and Property Insurance Company and Jimmy Willis Insurance Services, LLC (Dusty L. Dye and Rebecca H. Dye v. Allstate Vehicle and Property Insurance Company and Jimmy Willis Insurance Services, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dusty L. Dye and Rebecca H. Dye v. Allstate Vehicle and Property Insurance Company and Jimmy Willis Insurance Services, LLC, (N.D. Okla. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA DUSTY L. DYE and REBECCA H. DYE, ) ) Plaintiffs, ) ) v. ) Case No. 26-CV-0001-CVE-MTS ) ALLSTATE VEHICLE AND PROPERTY ) INSURANCE COMPANY and JIMMY ) WILLIS INSURANCE SERVICES, LLC, ) ) Defendants. ) OPINION AND ORDER Now before the Court are Defendant Jimmy Willis Insurance Services’ Motion to Dismiss for Fraudulent Joinder (Dkt. # 14) and Plaintiffs’ Motion to Remand and Brief in Support (Dkt. # 19). Defendant Allstate Vehicle and Property Insurance Company (Allstate) removed this case to federal court on the basis of diversity jurisdiction, even though plaintiffs and defendant Jimmy Willis Insurance Services, LLC (Willis) are citizens of Oklahoma. Dkt. # 2. Allstate argues that plaintiffs fraudulently joined Willis as a party to defeat diversity jurisdiction, because plaintiffs have not alleged any viable basis for recovery against Willis. Dkt. # 1, at 17-26. Plaintiffs ask the Court to remand this case to state court for lack of subject matter jurisdiction, because plaintiffs have asserted viable claims that Willis failed to procure the insurance policy they requested and Willis failed to ensure that plaintiffs actually qualified for the insurance policy issued by Allstate. Dkt. # 19, at 12- 14; Dkt. # 29, at 8-10. I. On June 10, 2025, plaintiffs Dusty L. Dye and Rebecca H. Dye filed this case alleging claims of breach of contract and breach of the covenant of good faith and fair dealing (bad faith) against Allstate following the partial denial of their insurance claim for wind and hail damage to their home. Dkt. # 2-2. Plaintiffs state that they are citizens of Oklahoma, and Allstate is incorporated in Illinois with its principal place of business in Illinois. Dkt. # 2, at 1; Dkt. # 2-2, at 1. Plaintiffs also asserted claims of negligent procurement of insurance and constructive fraud against Willis, and Willis is a citizen of Oklahoma. Dkt. # 2-2, at 16-21.

Plaintiffs allege that they contacted Willis to procure a homeowner’s insurance policy for their new home, and they state that they “requested Willis procure a full replacement cost policy that would in actuality provide coverage that would fully replace their home in the event of a loss without exclusions, deductions or loopholes for any weather-related losses.” Dkt. # 2-2, at 2. Plaintiffs claim that Willis represented that the policy issued by Allstate “would pay to replace anything and everything no matter what in the event of a catastrophe.” Id. at 2-3. Plaintiffs contend that Willis failed to advise them that the condition of their home could be a factor in the reduction or total exclusion of coverage under the policy. Id. at 5-6. Plaintiffs claim that Willis made an affirmative

representation that their new home was in good condition and satisfied all of Allstate’s underwriting guidelines. Id. at 6. Plaintiffs’ petition fails to include any allegations concerning when they initially contacted Willis for an insurance quote, but evidence provided by Allstate establishes that plaintiffs applied for homeowner’s coverage in August 2019. Dkt. # 27-1, at 1; Dkt. # 27-2, at 5. On June 17, 2023, a tornado struck plaintiffs’ home and caused significant damage to the roof, chimney, and exterior of the home. Id. at 8. Plaintiffs also claim the storm damaged wooden paneling and sheet rock inside the home, and additional damage to the attic and other interior spaces

was caused following the storm when a tarp on the roof proved ineffective to keep water out of the home. Id. Plaintiffs contacted Allstate the next day to file a claim under their homeowner’s 2 insurance policy. Id. Plaintiffs claim that Allstate sent a consultant who conducted a brief and inadequate investigation, and an Allstate adjustor concluded that more information was needed to evaluate plaintiffs’ claim. Id. at 8-9. Allstate sent an engineer to examine plaintiffs’ home on July 12, 2023, but the engineer did not issue a report concerning his findings until January 2024. Id. at 9. Plaintiffs consulted a chimney company to inspect their damaged chimney, and they were told

that total replacement of the chimney was the only viable option. Id. at 10. Plaintiffs claim that Allstate refused to pay for total replacement of the chimney on the grounds of pre-existing damage, wear and tear, and improper installation, and Allstate agreed to make only partial payments for damage to the roof, gutters, cosmetic repairs to the chimney, windows, and fence. Id. at 9-10. On June 10, 2025, plaintiffs filed this case alleging breach of contract and bad faith claims against Allstate, and they assert that the policy language mandates replacement coverage for all property suffering wind and hail damage. Id. at 12. Plaintiffs specifically allege that the language of the policy “does not make any distinction as to ‘cosmetic’ damage” but, instead, the policy

requires “benefits for replacement with like, kind quality.” Id. Plaintiffs contend that Allstate engages in a pattern or practice of undervaluing claims based on “outcome-oriented” investigations, although many of these allegations seem generic and not based on the specific conduct allegedly engaged in by Allstate when evaluating plaintiffs’ insurance claim. Id. at 13-16. Plaintiffs assert claims of negligent procurement of insurance and constructive fraud against Willis based on their allegations that they requested an insurance policy that would provide full replacement of any damaged property for any accidental loss or damage, and they allege that Willis failed to procure a

policy that would fully cover their property for all accidental losses without exclusions. Id. at 17-21.

3 Allstate removed the case to this court on the basis of diversity jurisdiction, even though plaintiffs and Willis are citizens of Oklahoma and it would appear that complete diversity of citizenship is lacking. Dkt. # 2. Allstate contends that plaintiffs fraudulently joined Willis as a party for the sole purpose of defeating diversity jurisdiction, because plaintiffs have not alleged a potentially viable claim against Willis. According to Allstate, plaintiffs allege that they requested

a replacement cost policy and admit in their petition that they actually were issued a replacement cost policy. Dkt. # 2, at 5. Allstate argues that Willis had no duty to explain the terms of coverage, and they cannot seek to hold Willis liable for negligent procurement if they failed to read the insurance policy before accepting it. Id. at 8. Plaintiffs assert that Willis should have inspected their property before submitting an application for insurance coverage, but Allstate argues that Oklahoma law imposes no duty on insurance agents to conduct underwriting on behalf of an insurance company before submitting an application for insurance coverage. Id. at 9. II.

Plaintiffs ask the Court to remand this case to state court, because they have alleged potentially viable claims against Willis and the parties are not completely diverse. Plaintiffs accuse Allstate of ignoring the allegations of their petition, and they argue that they have alleged that they clearly asked Willis to procure an insurance policy that would cover their home for replacement cost of any damage without any exclusions to coverage. Dkt. # 19, at 12. Plaintiffs also argue that Willis intentionally inflated the value of their home to increase insurance premiums, even though it should have known the home was older and would become “less insurable” due to age and deterioration.

Id. at 14. Allstate responds that it relied on the allegations of plaintiffs’ petition and removed the case to this Court due to the lack of potentially viable claims against Willis under Oklahoma law. 4 Dkt. #27, at 12.

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Bluebook (online)
Dusty L. Dye and Rebecca H. Dye v. Allstate Vehicle and Property Insurance Company and Jimmy Willis Insurance Services, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dusty-l-dye-and-rebecca-h-dye-v-allstate-vehicle-and-property-insurance-oknd-2026.