Evanston Insurance Company v. AmSpec Holding Corp.

CourtDistrict Court, S.D. Texas
DecidedOctober 20, 2020
Docket4:19-cv-01498
StatusUnknown

This text of Evanston Insurance Company v. AmSpec Holding Corp. (Evanston Insurance Company v. AmSpec Holding Corp.) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Evanston Insurance Company v. AmSpec Holding Corp., (S.D. Tex. 2020).

Opinion

October 20, 2020 UNITED STATES DISTRICT COURT David J. Bradley, Clerk SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

EVANSTON INSURANCE COMPANY, § § Plaintiff, § § v. § CIVIL ACTION NO. 4:19-CV-1498 § AMSPEC HOLDING CORP., § § Defendant. §

MEMORANDUM OPINION Pending before the Court1 is Defendant/Counterclaimant AmSpec Holding Corporation’s (“AmSpec”) Motion for Partial Summary Judgment (Dkt. No. 16) and Plaintiff/Counter-Defendant Evanston Insurance Company’s (“Evanston”) Motion for Summary Judgment (Dkt. No. 17). The Court has considered the motions, all other relevant filings, and the applicable law. For the reasons set forth below, the Court DENIES Defendant’s partial motion for summary judgment, and GRANTS Plaintiff’s motion for summary judgment. I. Background A. Factual Background The facts are largely undisputed. AmSpec performs testing and inspection services for oil, gas, and petrochemical industries.2 AmSpec field inspectors travel to ports, refineries, and terminals along the Gulf Coast where they inspect barges and vessels, and take product samples

1 The parties consented to proceed before the Undersigned Magistrate Judge for all proceedings, including trial and final judgment, pursuant to 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73. See Dkt. No. 28. 2 Dkt. No. 16-1 at 1. back to AmSpec laboratories for quality testing.3 1. The Policy4 Evanston issued a property insurance policy (the “Policy”) to AmSpec, effective from November 15, 2016 to November 15, 2017.5 The Policy insured multiple AmSpec buildings in Texas and provided coverage for business interruption,6 extra expense,7 and real and personal

property.8 The Policy also extended coverage to Dependent Locations: Dependent Locations – 1. Coverage – Coverage for earnings and/or extra expense is extended to loss of earnings or extra expenses that “you” incur during the “restoration period” when “your” “business” is interrupted by direct physical loss or damage, caused by a covered peril, to property at a “dependent location” described on the schedule.9

The Policy defines Dependent Locations as “locations that are operated by others and that ‘your’ ‘business’ depends on . . . .”10 The dependent locations at issue in the current case are the ports of Corpus Christi, Texas City, Galveston, Port Arthur, and Houston.11

3 Id. 4 For the purposes of this Memorandum Opinion, the Court will only address the portions of the Policy that are at issue in the instant case and relevant to the Court’s findings. 5 Dkt. No. 16-2 at 4. 6 “Business Interruption means loss resulting from necessary interruption of business conducted by the Insured and caused by direct physical loss or damage by any of the perils covered herein during the term of this policy to Real and/or Personal Property as covered herein.” Id. at 42. 7 Extra Expense means “the excess cost necessarily incurred to continue the operation of the Insured’s business or facility that would not have been incurred had there been no loss or damage by any of the perils covered herein during the term of this policy to Real and/or Personal Property as covered herein.” Id. at 43. 8 See id. at 41–43. 9 Id. at 71 (emphasis in original). 10 Id. 11 Dkt. No. 8 at 5. 2 / 19 The Policy also provided coverage for Interruption by Civil Authority: “We” extend “your” coverage for earnings and extra expense to include loss sustained while access to “covered locations” or a “dependent location” is specifically denied by an order of civil authority. This order must be a result of direct physical loss of or damage to property, other than at a “covered location” and must be caused by a covered peril.12

2. Timeline In preparation for a hurricane’s arrival, port conditions are used to alert the maritime community to changes in port operations. As explained in one of the bulletins, “[p]ort condition[s] are a gradual, time phased development based on [the] impact of [a] storm and assessment of safety conditions.”13 There are four possible port conditions: Whiskey (gale force winds possible within 72 hours), X-Ray (gale force winds possible within 48 hours), Yankee (gale force winds possible within 24 hours), and Zulu (gale force winds possible within 12 hours).14 Under port condition Zulu, a port is closed and all port operations are suspended.15 Below is a timeline of Hurricane Harvey’s development with the corresponding port conditions: - August 13, 2017 o Hurricane Harvey began as a tropical wave in the Atlantic Ocean.16 - August 17, 2017 o Hurricane Harvey developed into a tropical storm.17 - August 18, 2017 o Hurricane Harvey impacted the Windward islands and eventually weakened to a tropical wave.18

12 Dkt. No. 16-2 at 73. 13 Dkt. No. 16-9 at 2. 14 Id. at 2–3. 15 Id. at 3. 16 Major Hurricane Harvey, August 25-29, 2017 https://www.weather.gov/crp/hurricane_harvey (last visited September 22, 2020). 17 Id. 18 Id. 3 / 19 - August 22, 2017 o 1 p.m.: Corpus Christi’s Port was set to port condition Whiskey.19 - August 23, 2017 o Hurricane Harvey reformed and was predicted to make landfall as a hurricane somewhere along the Texas coast.20 - August 24, 2017 o Hurricane Harvey officially formed into a hurricane. o 6:57 p.m.: Ports of Houston, Texas City, Galveston, and Corpus Christi were set to port condition Yankee.21 - August 25, 2017 o 2 p.m.: Ports of Houston, Texas City, Galveston, and Corpus Christi were set to port condition Zulu and, thus, the ports were closed.22 o 10 p.m.: Hurricane Harvey made landfall in Texas.23 - August 28, 2017 o 6 p.m.: Port Arthur was set to port condition Zulu and, thus, the port was closed.24

3. The Claim On August 30, 2017, AmSpec sought coverage under the Policy for the following locations in Texas: Texas City; Pasadena; La Porte; Freeport; and Corpus Christi.25 On the same day, Evanston acknowledged the claim.26 Evanston retained independent adjusting firm Angle Martin & Associates to investigate the claim.27 AmSpec retained public

19 Dkt. No. 19-7 at 2. In reference to Dkt. No. 19-7, Evanston requested that the Court take judicial notice of these Coast Guard bulletins as “highly indisputable public records.” Dkt. No. 18 at 5 n.14. The Court “may judicially notice a fact that is not subject to reasonable dispute because it . . . can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.” Fed. R. Evid. 201(b)(2); see Matter of Manges, 29 F.3d 1034, 1042 (5th Cir. 1994) (taking judicial notice of certified copies of a deed in the public record). Because the proposed documents are highly indisputable public records, the Court takes judicial notice of them. 20 Dkt. No. 19-7 at 4; Major Hurricane Harvey, August 25-29, 2017 https://www.weather.gov/crp/hurricane_harvey (last visited September 22, 2020). 21 Dkt. No. 16-8 at 1. 22 See Dkt. No. 16-4 at 7; Dkt. No. 16-3 at 1. 23 Dkt. No. 16-4 at 1. 24 Dkt. No. 16-5 at 1. 25 See Dkt. No. 19-3; Dkt. No. 16 at 3; Dkt. No. 18 at 7. 26 See Dkt. No. 19-3 at 2. 27 Id. 4 / 19 adjuster Stephen Figlin (“Figlin”) with Young Adjustment.28 On January 3, 2019, Figlin submitted a statement to Evanston asserting that AmSpec’s property locations did not sustain damage, but that its claimed loss of business interruption and extra expense incurred as a result of the port closures.29 AmSpec claims a business interruption loss totaling $912,524.00 and an extra expense claim totaling $11,224.66 over a nine-day period

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Evanston Insurance Company v. AmSpec Holding Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/evanston-insurance-company-v-amspec-holding-corp-txsd-2020.