FIRST SOLAR ELECTRIC LLC v. ZURICH AMERICAN INSURANCE COMPANY

CourtDistrict Court, M.D. Georgia
DecidedApril 17, 2025
Docket5:21-cv-00408
StatusUnknown

This text of FIRST SOLAR ELECTRIC LLC v. ZURICH AMERICAN INSURANCE COMPANY (FIRST SOLAR ELECTRIC LLC v. ZURICH AMERICAN INSURANCE COMPANY) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
FIRST SOLAR ELECTRIC LLC v. ZURICH AMERICAN INSURANCE COMPANY, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION

FIRST SOLAR ELECTRIC, LLC ) ) Plaintiff, ) ) v. ) CIVIL ACTION NO. 5:21-cv-408 (MTT) ) ZURICH AMERICAN INSURANCE ) COMPANY, ) ) Defendant. ) )

ORDER On January 17, 2025, a jury found that Zurich American Insurance Company was liable to First Solar Electric, LLC for $12,238,060.61. Doc. 205. Zurich has now moved for judgment as a matter of law under Federal Rule of Civil Procedure 50(b) or, in the alternative, for a new trial under Rule 59(a). Doc. 215. Zurich has also moved to alter or amend the judgment under Rule 59(e). Doc. 216. For the following reasons, those motions are DENIED. I. BACKGROUND This case arises from a dispute over insurance coverage for flood damage to First Solar’s Twiggs County, Georgia solar construction project. Doc. 1. The underlying facts are discussed in detail in prior orders and will not be repeated here. See, e.g., Doc. 116. A jury trial was held from January 13 until January 17, 2025. Docs. 187; 198. Before trial, Zurich agreed that it owed First Solar $4,917,303.00 in liquidated damages. Doc. 200-2 ¶ 15. First Solar claimed Zurich owed it an additional $5,829,028.29 in unliquidated damages. Id. ¶ 14. The jury’s sole focus was First Solar’s unliquidated damages claim. The jury found against Zurich and awarded First Solar an additional $5,826,038.29 in unliquidated damages. Docs. 204 at 2; 205. The Court, pursuant to O.C.G.A. § 7-4-15, awarded pre-judgment interest on First Solar’s liquidated damages. Doc. 204 at 1-2. The jury, pursuant to O.C.G.A. § 13-6-13, awarded pre-judgment

interest on unliquidated damages. Id. at 2. First Solar’s total award was $12,238,060.61. Doc. 205. II. STANDARD A court may grant judgment as a matter of law “[i]f a party has been fully heard on an issue during a jury trial and the court finds that a reasonable jury would not have a legally sufficient basis to find for the party on that issue.” Fed. R. Civ. P. 50(a)(1). If a party timely moves for judgment as a matter of law “before the case is submitted to a jury,” it may renew its motion for judgment as a matter of law within 28 days after the entry of judgment. Fed. R. Civ. P. 50(b). In its renewed motion for judgment as a matter of law, a party may also include

an alternative request for a new trial under Rule 59. Id. “[U]nder Rule 59(a), a district court may, in its discretion, grant a new trial ‘if in [the court’s] opinion, the verdict is against the clear weight of the evidence…or will result in a miscarriage of justice, even though there may be substantial evidence which would prevent the direction of a verdict.” McGinnis v. American Home Mortgage Servicing, Inc., 817 F.3d 1241, 1254 (11th Cir. 2016) (quoting Hewitt v. B.F. Goodrich Co., 732 F.2d 243, 251 (11th Cir. 1940). Rule 59(e) also allows a party to move to amend the judgment within 28 days after the entry of judgment. “[T]he only grounds for granting a Rule 59 motion are newly-discovered evidence or manifest errors of law or fact.” Arthur v. King, 500 F.3d 1335, 1343 (11th Cir. 2007) (cleaned up). “A Rule 59(e) motion cannot be used to relitigate old matters, raise argument or present evidence that could have been raised prior to the entry of judgment.” Id.

III. DISCUSSION A. Judgment as a Matter of Law Zurich argues it is entitled to Judgment as a Matter of Law (1) because First Solar failed to provide sufficient evidence that the policy covered its damages as “Extra and Expediting Expenses;” (2) because First Solar’s claims were time-barred by the policy; and (3) because First Solar was not entitled to pre-judgment interest on its unliquidated damages. Doc. 215-1. 1. First Solar presented sufficient evidence that its damages were covered under the policy as extra and expediting expenses.

Zurich argues that First Solar did not provide sufficient evidence that its damages were covered under the policy’s coverage extensions for extra and expediting expenses. Doc. 215--1. Those provisions extended coverage to: (1) Expediting expenses, including any reasonable wages for overtime, night work, and work on public holidays and extra costs of express freight or other rapid means of transportation which are necessary to make temporary repairs and to expedite the permanent repair or replacement of the covered property when damaged by an peril insured, but only to the extent such is necessary to continue as nearly as practicable the normal operation of the work in progress.

(2) Extra expenses, which means the reasonable and necessary excess costs incurred during the period of restoration or repair of the damaged property that are over and above the total costs that would normally have been incurred during the same period of time had no loss or damage occurred for the purpose of continuing as nearly as practicable the scheduled progress of undamaged work. Any costs incurred hereunder shall be subject to the deductible applicable to the cause of loss that necessitates such costs. In the event that the amount of physical loss is less than the applicable deductible, the Company shall not accept a claim for, nor be liable for the excess costs as covered herein.

Doc. 201-1 at 16-17. Zurich raises five arguments as to why First Solar’s evidence was insufficient to meet the “elements” of each provision. Doc. 215-1 at 2, 3. Those arguments ignore evidence and misinterpret the policy. First, Zurich argues that First Solar failed to present evidence that its “expedited expenses” were for overtime, night work, work on public holidays, or express freight. Doc. 215-1 at 3. However, First Solar provided testimony and documentation to support its claims that overtime work was completed and that the overtime was reasonable and necessary to maintain the scheduled progress of work. See, e.g., Doc. 210 at 78:23- 80:20 (explaining that Exhibit P-163 reflects “all general conditions, per diem, overtime and double-time costs required” to complete the work on the scheduled dates). Second, Zurich argues that First Solar failed to prove the “period of restoration or repair” and is, thus, not entitled to extra expenses. Doc. 215-1 at 4. But Ted Garrett, the project manager, was asked if the damages were “incurred during the period of restoration and repair on this project?” and he responded “absolutely.” Doc. 210 at 179:18-20. Third, Zurich argues that First Solar failed to prove the amount of costs that “would normally have been incurred.” Doc. 215-1 at 4. However, Garrett testified that the expenses were “over and above” the normal costs. Docs. 210 at 179:21-24. Fourth, Zurich argues that First Solar did not prove it was entitled to extra expenses because First Solar’s expenses were not incurred to repair or replace “damaged property,” but rather to shift the work schedule so that First Solar could meet its overall deadline. Doc. 215-1 at 4. Zurich does not explain why the policy’s extra

expense provision would be limited to expenses incurred for direct repair or replacement of damaged property, and the policy’s language does not support that conclusion.

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Bluebook (online)
FIRST SOLAR ELECTRIC LLC v. ZURICH AMERICAN INSURANCE COMPANY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/first-solar-electric-llc-v-zurich-american-insurance-company-gamd-2025.