Feneck v. SBHU Life Agency Incorporated

CourtDistrict Court, D. Arizona
DecidedJune 12, 2024
Docket2:23-cv-01473
StatusUnknown

This text of Feneck v. SBHU Life Agency Incorporated (Feneck v. SBHU Life Agency Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Feneck v. SBHU Life Agency Incorporated, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 John V Feneck, No. CV-23-01473-PHX-ROS

10 Plaintiff, ORDER

11 v.

12 SBHU Life Agency Incorporated,

13 Defendant. 14 15 Plaintiff John Feneck filed this action against Defendant SBHU Life Agency Inc. 16 alleging negligence, breach of contract, and breach of the implied covenant of good faith 17 and fair dealing in connection with a lapsed life insurance policy. (Doc. 1, “Compl.”). 18 Defendant seeks dismissal of Plaintiff’s claims (Doc. 18, “Mot.”), arguing the claims fail 19 because Defendant had no duty to notify Plaintiff of impending lapses in coverage. 20 Because the complaint fails to state a claim, Defendant’s motion will be granted. The Court 21 will dismiss the complaint without prejudice and with leave to amend. 22 I. BACKGROUND 23 Plaintiff alleges the following relevant facts in the Complaint. In February 2002, 24 Plaintiff purchased a life insurance policy from Lincoln National Life Insurance Co. 25 (“Lincoln”) through Christopher Zimpo (a former employee of Defendant) on the lives of 26 his parents, providing for a $1 million death benefit to Plaintiff once both of his parents 27 passed away. Compl. ¶¶ 5–7. Plaintiff’s father has passed away, but his mother is still 28 alive. Id. at ¶ 8. Zimpo left Defendant’s employment soon after Plaintiff purchased the 1 policy. Id. at ¶ 9. 2 Plaintiff made timely quarterly payments on the policy until July 2021, paying 3 approximately $122,364.18 in premiums over that time span. Id. at ¶¶ 10–11. Lincoln 4 purportedly mailed two notices to Plaintiff at his home address and to Defendant in June 5 2021 and July 2021 stating he had to pay $2,749.89 before August 23, 2021 to prevent the 6 policy from lapsing. Id. at ¶¶ 13–14. Plaintiff alleges he did not receive these notices. Id. 7 Plaintiff made a regularly scheduled $2,500.00 payment toward the policy’s premiums in 8 late July 2021. Id. at ¶ 15. Lincoln purportedly mailed a third notice to Plaintiff and 9 Defendant on August 2, 2021 informing Plaintiff his $2,500.00 payment was less than the 10 $2,749.89 required to keep the policy active and again informing Plaintiff of the August 11 23, 2021 deadline for full payment. Id. at ¶ 16. Plaintiff alleges he did not receive this 12 notice until the “end of August 2021,” by which time the policy had lapsed. Id. at ¶¶ 17– 13 18. After receiving the August 2, 2021 notice, Plaintiff attempted to make the additional 14 $249.89 payment, but Lincoln refused to accept it, telling Plaintiff he could file for 15 reinstatement. Id. at ¶¶ 19–20. Plaintiff filed for reinstatement in September 2021 and was 16 denied in December 2021. Id. at ¶¶ 23–24. 17 II. MOTION TO DISMISS 18 A complaint must set forth a “short and plain statement of the claim showing that 19 the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “To survive a motion to dismiss, 20 a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to 21 relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting 22 Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (internal citations omitted)). If “the 23 well-pleaded facts do not permit the court to infer more than the mere possibility of 24 misconduct, the complaint” has not adequately shown the pleader is entitled to relief. Id. 25 at 679. Although federal courts ruling on a motion to dismiss “must take all of the factual 26 allegations in the complaint as true,” they “are not bound to accept as true a legal 27 conclusion couched as a factual allegation.” Id. at 678 (quoting Twombly, 550 U.S. at 555) 28 (internal quotations omitted). 1 Defendant moves to dismiss the complaint, arguing Defendant had no duty to notify 2 Plaintiff of lapses in insurance coverage and Plaintiff failed to adequately allege his 3 contract claims. Mot. at 6–8. 4 A. Negligence (Count I) 5 Count I of Plaintiff’s complaint alleges Defendant is liable for negligence because 6 Defendant breached its purported duty to properly notify Plaintiff of the underpayment 7 leading to lapse. Compl. ¶¶ 28–35. Defendant’s motion argues this claim fails because 8 insurance agents, who owe a duty to the insured in procuring insurance, see Darner Motor 9 Sales, Inc. v. Universal Underwriters Ins. Co., 682 P.2d 383, 397 (Ariz. 1984), have no 10 ongoing duty to prevent or warn of coverage lapses, see Mot. at 6. 11 Plaintiff argues “[c]ourts have held that an insurance agent may owe an ongoing 12 duty to an insured to notify the insured of a policy’s cancellation.” (Doc. 21 at 6, “Resp.”). 13 As Defendant points out in its reply, the two cases Plaintiff cites for this proposition are 14 distinguishable because Golden Rule involved policy recission due to an agent’s errors in 15 procuring the policy and Gist—which did not establish such a duty, but instead declined to 16 preclude the possibility of such a claim—was decided in a jurisdiction with no controlling 17 authority on the scope of an insurance agent’s duty. (Doc. 22 at 4–5, “Reply”) (citing 18 Golden Rule Ins. Corp. v. Greenfield, 786 F. Supp. 914 (D. Colo. 1992) and Gist v. Aetna 19 Cas. and Sur. Co., 641 F. Supp. 539 (W.D. Ark. 1986)). 20 Plaintiff next argues the collection of cases Defendant cites in arguing no ongoing 21 duty on agents exists are inapposite because they are summary judgment rulings, not 22 decisions on motions to dismiss. Resp. at 6. Although none of these cases from various 23 state courts outside Arizona are binding in this matter, the procedural posture of the 24 authority is immaterial because the holdings of the cited cases “present the scope of the 25 legal duty,” as Defendant argues in its reply. Reply at 5. Whether a duty is owed is a 26 threshold question properly adjudicated on a motion to dismiss. See Gipson v. Kasey, 150 27 P.3d 228, 230 (2007) (“Whether the defendant owes the plaintiff a duty of care is a 28 threshold issue; absent some duty, an action for negligence cannot be maintained.”). 1 Plaintiff has not demonstrated Arizona law imposes any sort of continuing duty on 2 an insurance agent related to ensuring continuity of policies long after procurement. 3 Plaintiff’s complaint thus fails to state a claim for negligence against Defendant. The Court 4 will grant Defendant’s motion with respect to Count I. 5 B. Breach of contract (Count II) 6 Count II of Plaintiff’s complaint alleges Defendant breached a contract with 7 Plaintiff by failing to properly notify Plaintiff of the insurance policy’s premium payment 8 delinquencies to prevent lapse. Compl. ¶¶ 36–41. Defendant argues Plaintiff’s breach of 9 contract claim fails because Plaintiff has not pled sufficient facts to give rise to a prima 10 facie case of breach of contract. Mot. at 7. To prevail on a breach of contract claim under 11 Arizona law, a plaintiff must prove: (1) a valid contract existed; (2) breach; and (3) 12 damages. Graham v. Ashbury, 540 P.2d 656, 657 (Ariz. 1975). 13 Defendant argues Plaintiff has not identified any contract between Defendant and 14 Plaintiff because Plaintiff’s complaint fails to allege any terms of the contract, when it was 15 entered into, or how it required Defendant to provide notices to Plaintiff, alleging only that 16 Plaintiff and Defendant “entered into a contract through which [Defendant] agreed to 17 provide insurance agent services to [Plaintiff].” Mot. at 7–8 (citing Compl.

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Feneck v. SBHU Life Agency Incorporated, Counsel Stack Legal Research, https://law.counselstack.com/opinion/feneck-v-sbhu-life-agency-incorporated-azd-2024.