ENWONWU v. INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB

CourtDistrict Court, D. Maine
DecidedSeptember 19, 2025
Docket2:24-cv-00055
StatusUnknown

This text of ENWONWU v. INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB (ENWONWU v. INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ENWONWU v. INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB, (D. Me. 2025).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF MAINE

FRANCIS OBIORA ENWONWU, ) ) Plaintiff, ) ) v. ) 2:24-cv-00055-SDN ) INTERINSURANCE EXCHANGE ) OF THE AUTOMOBILE CLUB, ) ) Defendant. )

ORDER Plaintiff Francis Enwonwu sued his car insurance company, the Interinsurance Exchange of the Automobile Club (more commonly known as AAA1), after it denied a claim. Prior to the denial, Mr. Enwonwu had failed to make payments on his insurance policy, so AAA cancelled it. A few weeks later, Mr. Enwonwu called AAA to reinstate his policy. He falsely told AAA he had not been in any accidents while the policy had lapsed, so AAA reinstated his policy retroactively. In fact, just two hours before he had called AAA to reinstate his policy, Mr. Enwonwu had been in a car accident. When AAA learned of Mr. Enwonwu’s deceit, it refused to pay the claim and cancelled Mr. Enwonwu’s insurance policy. Mr. Enwonwu claims AAA was wrong to deny his claim and cancel his policy. Now, AAA moves for summary judgment. Mr. Enwonwu, who represents himself, also filed his own motion for summary judgment, although for the reasons discussed further below, that motion is untimely and procedurally improper. For the following reasons, AAA’s motion is granted and Mr. Enwonwu’s motion is denied.

1 The defendant refers to itself in filings as AAA, so I do too. FACTUAL BACKGROUND I. Local Rule 56 Before laying out the facts, I briefly address Mr. Enwonwu’s failure to abide by District of Maine Local Rule 56. Local Rule 56 governs summary judgment motions by outlining a basic process litigants must follow. First, the movant must support their

motion with “a separate, short, and concise statement of material facts, each fact in a separately numbered paragraph.” D. Me. Local R. 56(b). Each statement must be “stated simply and directly” and “supported by a record citation.” Id. Then, the opponent must submit their own “short[] and concise statement of material facts.” D. Me. Local R. 56(c). In doing so, the opponent must respond to the movant’s statement by admitting, denying, or qualifying each of the movant’s facts, with “reference to each numbered paragraph.” Id. If the opponent adds new, additional facts, the movant gets a chance to reply. D. Me. Local R. 56(d). This process exists for a reason. Summary judgment is a unique device that “allows courts and litigants to avoid full-blown trials in unwinnable cases, thus conserving the parties’ time and money,” and saving judicial resources. Calvi v. Knox Cnty., 470 F.3d

422, 427 (1st Cir. 2006) (quoting McCarthy v. Northwest Airlines, Inc., 56 F.3d 313, 315 (1st Cir. 1995)). At the same time, “litigants with marginal or unwinnable cases” can abuse the summary judgment device to hide behind the mountains of evidence even simple cases can produce. Id. Local rules like ours help “dispel the smokescreen” and focus the court’s attention “on what is—and what is not—genuinely controverted.” Id. The First Circuit therefore has repeatedly “emphasized the importance of local rules similar to Local Rule 56.” Caban Hernandez v. Philip Morris USA, Inc., 486 F.3d 1, 7 (1st Cir. 2007) (referring to the District of Puerto Rico’s local rule). And the First Circuit has repeatedly cautioned that “litigants ignore them at their peril.” Id. When the party opposing summary judgment fails to comply with the local rules, a district court is free “to accept the moving party’s facts as stated.” Id. Mr. Enwonwu did not file an opposing statement of material facts that complies with Local Rule 56(c). While his response to AAA’s motion occasionally cites AAA’s

statement of material facts, it does not clearly admit or deny any particular facts. To be sure, courts endeavor to treat unrepresented litigants like Mr. Enwonwu with a large degree of leniency. See, e.g., Estelle v. Gamble, 429 U.S. 97, 106 (1976). At the same time, it is not fair to defendants if courts perform “the plaintiff’s work of identifying whether there are any triable issues of fact.” Kristiansen v. Town of Kittery, No. 18-cv- 00420, 2021 WL 4073273, at *4 (D. Me. Sept. 6, 2021) (R&R). A court “must be able to rely on procedural rules so as to avoid becoming the lawyer for the unrepresented plaintiff.” Clarke v. Blais, 473 F. Supp. 2d 124, 129 (D. Me. 2007). This is particularly true where an unrepresented party is actually aware of the procedural rules they disregard. Mr. Enwonwu notes in his opposition that “the Court’s procedural order required . . . that plaintiff separately file[] a statement of material facts

in support of its opposition to defendant’s summary judgment.” ECF No. 48 at 4 (emphasis added).2 Instead of doing so, however, Mr. Enwonwu “point[ed] out to this Court false fabrication[s] used by this defendant in supporting their alleged recorded evidence in their ‘DSMF’[,] referenced herein.” Id. This is insufficient. Because Mr. Enwonwu failed to comply with Local Rule 56(c) by improperly responding to AAA’s statement of material facts, I deem those facts admitted. Caban

2 I use the page numbers on the bottom of Mr. Enwonwu’s opposition brief rather than the page numbers in the ECF header. Hernandez, 486 F.3d at 7. Nonetheless, because Mr. Enwonwu is an unrepresented litigant, I “have reviewed the broader record to satisfy myself that it supports” what AAA says it does. Murray v. Walmart Stores Inc., No. 15-CV-00484, 2019 WL 6689900, at *5 (D. Me. Dec. 6, 2019). II. The Facts

AAA issued Mr. Enwonwu an auto insurance policy on November 18, 2021. DSMF ¶ 1.3 He did not pay his premium on time as required by the policy. Id. ¶ 2. On December 28, 2021, AAA sent him a letter confirming his failure to pay and warning him that AAA would cancel his policy if it did not receive payment by January 16, 2022. Id. ¶¶ 2–3; ECF No. 46-3 (notice letter). On January 7, 2022, AAA representatives emailed and called Mr. Enwonwu to remind him, leaving voice messages on his phone, DSMF ¶ 4, but he did not respond to the letters, emails, or phone calls. Id. ¶ 5. Nor did he pay his premium by January 16, 2022. Id. Accordingly, on that day, AAA cancelled Mr. Enwonwu’s policy and sent him a cancellation notice. Id. ¶ 6; ECF No. 46-4 (notice of cancellation). Two weeks later, on January 29, 2022, at 4:45 p.m., Mr. Enwonwu called AAA and asked to have his insurance policy reinstated. DSMF ¶ 7. To determine whether

reinstatement was appropriate, AAA asked Mr. Enwonwu on the call whether he had been in any car accidents in the time between January 16th (when his policy was cancelled) and his call on January 29th (when he sought reinstatement). Id. ¶ 8. Mr. Enwonwu claimed he had not been in any accidents during that period. Id. ¶ 9. Based on that representation, AAA reinstated his policy with retroactive effect to January 16th. Id. ¶¶ 10, 12.

3 DSMF refers to the Defendant’s Statement of Material Facts, ECF No. 44. Contrary to what he had told AAA, Mr. Enwonwu had been in a car accident at approximately 2:45 p.m. on January 29, 2022, just two hours before he called AAA to reinstate his policy. Id. ¶ 11. The other vehicle in the accident was owned by Audet Enterprises, Inc., which filed a claim against Mr. Enwonwu on January 30, 2022. Id. AAA’s underwriting team reviewed the matter and determined that Mr. Enwonwu’s

misrepresentations materially affected AAA’s ability to insure him. Id. ¶¶ 13, 14. Indeed, AAA would not have retroactively reinstated Mr. Enwonwu’s policy had it known about the accident. Id. ¶¶ 16, 18. Accordingly, for that reason alone, AAA cancelled Mr. Enwonwu’s policy again and denied Audet’s claim.

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ENWONWU v. INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/enwonwu-v-interinsurance-exchange-of-the-automobile-club-med-2025.