ERIKA MCDADE v. JUSTIN R. BENOIT & Others.

CourtMassachusetts Appeals Court
DecidedNovember 6, 2023
Docket22-P-1120
StatusUnpublished

This text of ERIKA MCDADE v. JUSTIN R. BENOIT & Others. (ERIKA MCDADE v. JUSTIN R. BENOIT & Others.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ERIKA MCDADE v. JUSTIN R. BENOIT & Others., (Mass. Ct. App. 2023).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

22-P-1120

ERIKA MCDADE 1

vs.

JUSTIN R. BENOIT & others. 2

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

In this unfair settlement practices action, Erika McDade

claims that Safety Insurance Company (Safety) violated the

requirements of G. L. c. 93A and G. L. c. 176D by failing to

offer her a reasonable settlement following a car accident

between McDade and Safety's insured. After a bench trial on

these claims, a Superior Court judge found that Safety made

reasonable offers to McDade based on its assessment of her

injuries and comparative fault and thus did not engage in unfair

settlement practices. Judgment entered accordingly for Safety,

and McDade appeals. We affirm.

Background. In August 2013 Justin Benoit, a driver for

Brodie, Inc., made a left turn across McDade's lane of travel to

1 Formerly known as Erika McKenzie. 2 Brodie, Inc., and Safety Insurance Company. turn into a parking lot. McDade struck the rear side of

Benoit's truck, sustaining damage to her car. An ambulance

transported McDade to the emergency room, and she was later

treated for neck and back pain. Brodie, Inc., was insured by

Safety.

Safety opened a claim on the accident and assigned

Christina Parsons, a veteran claims adjuster, to the accident

file. Parsons took a statement from McDade, who reported that

her neck and back issues from the accident required her to quit

her part-time nannying job and seek regular chiropractic care.

McDade further reported that she missed three days of work as a

nurse before returning full time.

Parsons also spoke to two eyewitnesses, Sonja Houle and

Charles Sidden. Houle, who was driving behind McDade and saw

Benoit's truck make the left turn, stated that McDade seemed a

"little late" in applying her brakes. Sidden, who was driving

behind the truck, stated that the truck was three-quarters of

the way into the parking lot when McDade hit it. Based in part

on these statements, Parsons determined that McDade had some

liability for the accident and informed her that Safety would

pay for eighty percent of the property damage.

Upon assigning eighty-percent liability to Benoit, Parsons

set an initial loss reserve amount of $7,929 for McDade's bodily

injury claim. The loss reserve was meant to represent the

2 "worst-case scenario" for Safety. The initial loss reserve

amount was based on McDade's ambulance ride to the emergency

room, her negative x-rays, and her chiropractic care. By April

2014 Parsons increased the loss reserve to $15,000 after

McDade's insurer, Commerce Insurance Company (Commerce),

reported that McDade's medical bills exceeded $8,000. Later

that year, after Commerce made a subrogation demand, the matter

went to intercompany arbitration at which the arbitrator found

that Safety's position that its insured was eighty percent

liable was a "reasonable compromise" given the circumstances of

the accident.

In March 2015 Safety received a demand for $150,000 from

McDade. The demand included a medical report from Dr. George

Kasparyan, a nontreating orthopedic surgeon, who diagnosed

McDade with chronic pain syndrome and chronic cervical,

thoracic, and lumbar sprain. Based on the American Medical

Association (AMA) guidelines, Dr. Kasparyan opined that McDade

had a twenty-two percent "permanent partial impairment of the

whole person." The demand also included documented medical

expenses of $11,513.75 and stated that McDade had $535 in lost

earnings.

In response to the demand, Parsons increased the loss

reserve to $40,000, and Safety retained a medical expert to

review McDade's medical records. After McDade later reduced her

3 demand to $130,000, Safety countered with an offer of $12,000,

justifying that amount based on its attribution of some fault to

McDade and its disagreement with the extent of her injuries.

Soon thereafter, Safety received a report from its medical

expert, who opined that the "records provided no objective

finding of an 'anatomic abnormality' causally related to the

accident." Safety then retained a second expert, Dr. Ryan

Friedberg, to obtain an opinion regarding Dr. Kasparyan's

conclusion that McDade had a permanent whole person impairment

of twenty-two percent.

Safety was waiting to hear from Dr. Friedberg when McDade

sent a c. 93A demand letter in September 2015. A few days

later, Safety received Dr. Friedberg's report in which he

concluded that McDade's diagnoses of cervical, thoracic, and

lumbar strain were causally related to the accident, but that it

would be unusual to classify for permanency based on those

injuries. Dr. Friedberg also opined that Dr. Kasparyan's

finding of a twenty-two percent whole person impairment was

"significantly exaggerated" and that that figure would more

likely be between two and eight percent.

Parsons conducted an updated valuation of McDade's claim

based on Dr. Friedberg's report. Parsons estimated the claim

range to be between $11,405 and $16,182 considering McDade's

comparative negligence, the soft tissue nature of her injuries,

4 the lack of objective diagnostic testing, and the fact that she

missed only three days of work. The approved range was up to

$18,000. After crediting certain amounts based on Dr.

Friedberg's assessment of McDade's whole body impairment,

Parsons recommended increasing the offer to $15,000. William

Bradley, Parsons's supervisor, reviewed and approved the offer.

When the parties were unable to reach a settlement, McDade

filed suit in October 2015. Id. During discovery Dr. Friedberg

performed a medical examination of McDade, after which he

concluded that her medical treatment was reasonable through

March 2014, when she came to a "medical endpoint." Dr.

Friedberg again opined that Dr. Kasparyan's finding of a

permanent whole person impairment of twenty-two percent was

"significantly exaggerated" and not consistent with the AMA

guidelines. In addition, Dr. Friedberg explained in his

deposition that the permanency designation under the AMA

guidelines means that improvement is not expected over a one-

year timeframe, not that the impairment will necessarily persist

over a person's lifetime.

The underlying tort claim proceeded to a jury trial in

January 2018. The jury found that the defendants were negligent

and that McDade was not comparatively negligent and awarded her

damages of $225,000.

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ERIKA MCDADE v. JUSTIN R. BENOIT & Others., Counsel Stack Legal Research, https://law.counselstack.com/opinion/erika-mcdade-v-justin-r-benoit-others-massappct-2023.