Farina v. Conestoga Title Insurance

81 Pa. D. & C.4th 548
CourtPennsylvania Court of Common Pleas, Lancaster County
DecidedNovember 10, 2006
Docketno. CI-05-04931
StatusPublished

This text of 81 Pa. D. & C.4th 548 (Farina v. Conestoga Title Insurance) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lancaster County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Farina v. Conestoga Title Insurance, 81 Pa. D. & C.4th 548 (Pa. Super. Ct. 2006).

Opinion

GEORGELIS, J.,

Before me is the motion for summary judgment of the defendant, Conestoga Title Insurance Company. The plaintiff, Francis J. Farina, has brought this action against Conestoga for damages he has alleged were caused by Conestoga’s [550]*550failure to inform him of the presence of a septic tank on his property. The motion will be granted.

In July of 1992, Farina purchased title insurance from Conestoga for the purchase of a home in Chester County. In April of 2005, Farina learned that a neighbor sustained damage to his property as a result of a collapsed septic tank. Farina, concerned that his property might also contain a septic tank, searched the Tredyffrin Township record of sanitary drainage and plumbing fixtures and discovered that his property also contained a septic tank. He contacted Conestoga and made a claim against his title insurance policy for the removal of the septic tank. Conestoga denied the claim for the reason that it was not covered by Farina’s policy.

On June 10, 2005, Farina filed a complaint as a class action and sought certification of the proposed class. On January 5,2006, he filed a motion for class certification, pursuant to Pa.R.C.P. 1701 et seq., and Conestoga filed its answer on January 13, 2006. On May 11, 2006, Farina again filed a motion for class certification with an amended memorandum of law, and Conestoga filed a brief of opposition to the motion on June 2, 2006. Both parties agreed to waive the Pa.R.C.P. 1707 hearing and, on July 19, 2006,1 heard oral argument. On August 9, 2006,1 denied the motion for class certification.

Farina’s complaint contains five counts: violation of the Unfair Insurance Practices Act (UIPA), 40 Pa.C.S. §1171 et seq.; breach of contract; fraudulent misrepresentation; breach of duty of good faith and fair dealing; and declaratory relief. Conestoga seeks summary judgment on all of these counts.

Summary judgment is proper when the pleadings, depositions, answers to interrogatories and admissions [551]*551on file, together with any affidavits, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law. Pa.R.C.P. 1035.2; Kuney v. Benjamin Franklin Clinic, 751 A.2d 662, 664 (Pa. Super. 2000). “The moving party has the burden of proving that no genuine issue of material fact exists.” Accu-Weather Inc. v. Prospect Communications Inc., 435 Pa. Super. 93, 99, 644 A.2d 1251, 1254 (1994). “In summary judgment cases, review of the record must be conducted in the light most favorable to the non-moving party, and all doubts regarding the existence of a genuine issue of material fact must be resolved against the moving party.” Young v. PennDOT, 560 Pa. 373, 376, 744 A.2d 1276, 1277 (2000).

1. COUNT I — VIOLATION OF THE UNFAIR INSURANCE PRACTICES ACT

In seeking summaiy judgment on Count I of the complaint, Conestoga contends that Farina does not have standing to state a claim under the UIPA. Our Superior Court has held that the insurance commissioner is the proper authority to enforce the UIPA and that the Act does not confer a right of private action. Kramer v. State Farm Fire and Casualty Insurance Company, 412 Pa. Super. 227, 603 A.2d 192 (1992); Hardy v. Pennock Insurance Agency Inc., 365 Pa. Super. 206, 529 A.2d 471 (1987).

Farina cites Pennsylvania case law for the proposition that a violation of the Unfair Trade Practices Consumer Protection Law (UTPCPL), 73 P.S. §201-1 et seq., constitutes a violation of the UIPA. I do not believe those cases stand for that proposition. In Wright v. North American Life Assurance Company, 372 Pa. Super. 272, [552]*552279, 539 A.2d 434, 438 (1988), our Superior Court held that the UIPA does not confer a right of private action but that an insured could pursue claims based on common-law fraud and misrepresentation theories. In Pekular v. Eich, 355 Pa. Super. 276, 282-83, 513 A.2d 427, 430 (1986), our Superior Court held that: the UIPA vests the insurance commissioner with the power to investigate specifically defined acts and practices of insurers; the UIPA is not the exclusive means by which an insured can address an insurer’s unfair or deceptive acts; and an insured may maintain a private cause of action under the UTPCPL.

In Count I of his complaint, Farina has identified a claim under the UIPA and avers that he is entitled to relief under that Act because Conestoga’s violations of that Act constitute violations of the UTPCPL. In contending that Conestoga is not entitled to summary judgment on this claim, he has cited case law which he asserts supports the position that a violation of the UTPCPL is a violation of the UIPA. That is, A (a violation of the UIPA) leads to B (a violation of the UTPCPL), and B leads to A. It appears that he is alleging that Conestoga has violated both Acts and that claims under the two Acts are interchangeable. That is not the law in our Commonwealth.

In Kramer and Hardy, our Superior Court has held that the UIPA does not confer the right of a private action. In Wright and Pekular, it held similarly and also that an insured can pursue a claim of unfair or deceptive acts under common-law fraud theories or under the UTPCPL. Farina has pled a cause of action under the UIPA, and, accordingly, Conestoga is entitled to summary judgment on that count.

[553]*5532. COUNT II — BREACH OF CONTRACT

In seeking summary judgment on Count II of the complaint, Conestoga contends that the existence of the septic tank did not cause a defective title; it did not have a duly to search municipal records; and, therefore, it did not breach the insurance contract.

Farina contends that: (1) the existence of the septic tank caused a defect in the marketability of the title to his property; (2) because the title insurance policy required Conestoga to research all records that could affect the marketability of the title, Conestoga breached the contract when it failed to research municipal records regarding septic tanks; (3) the existence of the septic tank negatively impacts the marketability of the title; and (4) Conestoga’s denial of his policy claim constitutes a breach of contract.

Title insurance protects a buyer from loss occurring from defects in the title of the property he acquires. Hicks v. Saboe, 521 Pa. 380, 384, 555 A.2d 1241, 1243 (1989). “A contract of title insurance is an agreement to indemnify against loss through defects of title.” Trigiani v. American Title Insurance Company, 392 Pa. Super. 427, 430, 573 A.2d 230, 231 (1990) (quoting

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Bluebook (online)
81 Pa. D. & C.4th 548, Counsel Stack Legal Research, https://law.counselstack.com/opinion/farina-v-conestoga-title-insurance-pactcompllancas-2006.