Edleson v. Travel Insured International, Inc.

CourtDistrict Court, S.D. California
DecidedMarch 8, 2022
Docket3:21-cv-00323
StatusUnknown

This text of Edleson v. Travel Insured International, Inc. (Edleson v. Travel Insured International, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edleson v. Travel Insured International, Inc., (S.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 10 LOUIS B. EDLESON, on behalf Case No.: 21-cv-0323-WQH-AGS of himself and all others similarly 11 situated, ORDER 12 Plaintiff, 13 v. 14 TRAVEL INSURED 15 INTERNATIONAL, INC., and UNITED STATES FIRE 16 INSURANCE COMPANY, 17 Defendants. 18 HAYES, Judge: 19 The matter before the Court is the Motion to Dismiss Plaintiff’s request for 20 injunctive relief, filed by Defendants Travel Insured International, Inc. and United States 21 Fire Insurance Company. (ECF No. 35). 22 I. PROCEDURAL BACKGROUND 23 On February 23, 2020, Plaintiff Louis B. Edleson filed a Class Action Complaint 24 against Defendants Travel Insured International, Inc. (“Travel Insured”) and United States 25 Fire Insurance Company (“U.S. Fire”), alleging that Defendants violated California state 26 law by failing to refund travel insurance premiums paid for post-departure coverage on 27 trips that were never taken. 28 1 On May 3, 2021, Defendants filed a Motion to Dismiss the Complaint for lack of 2 standing and for failure to state a claim under Rules 12(b)(1) and 12(b)(6) of the Federal 3 Rules of Civil Procedure. (ECF No. 20). On September 23, 2021, the Court issued an 4 Order granting in part and denying in part Defendants’ Motion to Dismiss. (ECF No. 27). 5 The Order dismissed Plaintiff’s request for injunctive relief for lack of Article III standing. 6 (See id. at 11-12). 7 On December 1, 2021, Plaintiff filed the operative First Amended Complaint 8 (“FAC”). (ECF No. 34). On December 14, 2021, Defendants filed a Motion to Dismiss 9 the repleaded request for injunctive relief for lack of standing under Rule 12(b)(1) of the 10 Federal Rules of Civil Procedure. (ECF No. 35). On January 4, 2022, Plaintiff filed an 11 Opposition in response to the Motion to Dismiss. (ECF No. 36). On January 11, 2022, 12 Defendants filed a Reply. (ECF No. 37). 13 II. ALLEGATIONS IN THE FAC 14 Plaintiff purchased a travel insurance plan (the “Plan”) administered by Defendant 15 Travel Insured and underwritten by Defendant U.S. Fire in connection with a cruise 16 scheduled for October 10, 2020. The Plan included pre-departure coverage for non- 17 refundable travel costs and several types of post-departure coverage. The post-departure 18 coverage was not effective until the commencement of the cruise. 19 After Plaintiff’s cruise was cancelled due to the COVID-19 pandemic, Plaintiff 20 requested a refund of the Plan’s premium. Defendants “were obliged to return that portion 21 of the gross premium that [Plaintiff] paid for benefits exclusively covering post-departure 22 risks.” (ECF No. 34 ¶ 52). However, Travel Insured refused to refund the premium and 23 instead “only offered a voucher for use on future travel insurance, which was limited in 24 duration and, thus, was worthless at the time because the COVID-19 pandemic made any 25 travel impossible at that time.” (Id. ¶ 50).1 26

27 1 Defendants request that the Court take judicial notice of a document containing an email message from 28 1 Plaintiff intends to resume travel once it is safe and advisable to do so. Plaintiff also continues to desire to purchase travel insurance to protect any 2 future travel purchase from pre- and post-departure risks. However, Plaintiff 3 is cognizant of the fact that the effects of the pandemic could be long-lasting and that associated travel restrictions and trip cancellations could happen at 4 any time based on changed circumstances. As such it is important to Plaintiff 5 that any travel insurance that he may purchase in the future provide for pro rata refunds of premiums attributable to post-departure coverage should the 6 trip be cancelled prior to departure. Were Travel Insured to provide pro rata 7 refunds of premiums attributable to post-departure coverage in the event that the trip is cancelled prior to departure, as Travel Insured is already required to 8 under the law, Plaintiff would purchase any such trip insurance policy from 9 Travel Insured. However, at the moment, Plaintiff has no way of determining whether Travel Insured will provide him with a pro rata refund of premiums 10 attributable to post-departure coverage in the event that the trip is cancelled 11 prior to departure. Thus, injunctive relief is necessary to prevent future harm to Plaintiff and the Class and to ensure that Travel Insured complies with its 12 obligations under the law for providing refunds. 13 (Id. ¶¶ 54-55). 14 Plaintiff brings the following individual and class claims against Defendants: (1) 15 unjust enrichment; and (2) violation of California’s Unfair Competition Law, Cal. Bus. & 16 Prof. Code §§ 17200, et seq. Plaintiff seeks damages, restitution, injunctive relief, and 17 attorneys’ fees and costs. 18 III. CONTENTIONS 19 Defendants contend that Plaintiff fails to allege a cognizable future injury for the 20 purpose of establish standing for injunctive relief under Rule 12(b)(1) of the Federal Rules 21 of Civil Procedure. Defendants contend that there is no “real and immediate threat of 22 injury” because Plaintiff no longer has the Plan, has not purchased a new plan, has not 23

24 25 connection with a new or rescheduled trip “up to 24 months from [the] original date of departure” of Plaintiff’s original trip. (Ex. A to Motion to Dismiss, ECF No. 35-2 at 2). Plaintiff does not dispute the 26 authenticity of the document or Defendants’ request for judicial notice in his Opposition. The Court grants Defendants’ request for judicial notice. See Branch v. Tunnell, 14 F.3d 449, 454 (9th Cir. 1994), overruled 27 on other grounds by Galbraith v. County of Santa Clara, 307 F.3d 1119 (9th Cir. 2002) (“[D]ocuments whose contents are alleged in a complaint and whose authenticity no party questions, but which are not 28 1 booked travel for which a plan could be purchased, and has rejected a voucher that he could 2 use to purchase a future plan. (ECF No. 35-1 at 13). Defendants contend that Plaintiff’s 3 allegations regarding future harm are speculative because “Plaintiff fails to offer any 4 specific allegations of when in the future he might travel . . . .” (Id.). Defendants contend 5 that any future harm is avoidable by Plaintiff because he now knows that Travel Insured 6 does not offer the type of refund Plaintiff seeks. Defendants contend that the reasoning in 7 Davidson v. Kimberly-Clark Corp., 889 F.3d 956 (9th Cir. 2018), is limited to false 8 advertising claims and that even under Davidson, Plaintiff fails to allege a future injury 9 that is real and immediate. 10 Plaintiff contends that the FAC adequately alleges facts demonstrating that Plaintiff 11 has standing to seek injunctive relief under Davidson, which is not limited to false 12 advertising claims or informational injuries. Plaintiff contends that an allegation that he 13 would purchase a travel insurance plan from Defendants in the future if it provided for a 14 refund is sufficient to establish standing. Plaintiff contends that there is no requirement 15 “that the plaintiff currently have a product with the defendant or that the plaintiff have a 16 concrete plan for when he or she will purchase the product.” (ECF No. 36 at 10). Plaintiff 17 contends that the FAC challenges Defendants’ continued conduct and that Plaintiff can 18 demonstrate a concrete injury despite Plaintiff’s knowledge of Travel Insured’s existing 19 policies. 20 IV. LEGAL STANDARD 21 Rule 12(b)(1) of the Federal Rules of Civil Procedure

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Bluebook (online)
Edleson v. Travel Insured International, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/edleson-v-travel-insured-international-inc-casd-2022.