FRANCO v. PROGRESSIVE CASUALTY INSURANCE COMPANY

CourtDistrict Court, M.D. North Carolina
DecidedMay 14, 2025
Docket1:24-cv-00225
StatusUnknown

This text of FRANCO v. PROGRESSIVE CASUALTY INSURANCE COMPANY (FRANCO v. PROGRESSIVE CASUALTY INSURANCE COMPANY) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
FRANCO v. PROGRESSIVE CASUALTY INSURANCE COMPANY, (M.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

MAYRA FRANCO, individually and ) on behalf of a class of similarly ) situated persons, ) ) Plaintiff, ) ) v. ) 1:24-CV-225 ) PROGRESSIVE CASUALTY ) INSURANCE COMPANY AND ) PROGRESSIVE SOUTHEASTERN ) INSURANCE COMPANY, ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Catherine C. Eagles, Chief District Judge. The plaintiff, Mayra Franco, submitted a claim to her insurer, defendant Progressive Southeastern Insurance Company, after her 2004 Jeep Grand Cherokee was totaled. She alleges that Progressive Southeastern underpaid her claim and that defendant Progressive Casualty Insurance Company, which manages and controls the insurance claims process for Progressive affiliates, systematically underpays insureds who submit a total-loss claim by the arbitrary and illegal use of a “projected sold adjustment” (PSA). Based on this conduct, she asserts a claim under the North Carolina Unfair and Deceptive Trade Practices Act, and she seeks to certify a class of all Progressive insureds whose total-loss claims were adjusted with the inclusion of a PSA. She has satisfied the Rule 23 requirements, and her motion for class certification will be granted. I. Facts and Background Progressive Southeastern is an insurance company that underwrites automobile liability and collision insurance in North Carolina. See Doc. 53 at 17–20;1 Doc. 45-9.

Progressive Casualty adjusts all vehicle total-loss claims in North Carolina for its underwriting affiliates, see Doc. 53 at 14–16, 19–20; Doc. 47-1 at 11; Doc. 45-13 at ¶ 9, including Progressive Southeastern. See Doc. 53 at 19–20; Doc. 59-1 at ¶ 1. For ease of reading, the Court will hereafter refer to the defendants collectively as “Progressive.” In 2023, Ms. Franco was in a car accident that resulted in the total loss of her 2004

Jeep Grand Cherokee. Doc. 62-1 at 8, 11; see Doc. 45-7. At the time, she had an insurance policy with Progressive, and she submitted a claim. Id. at 11. Progressive’s policy provides that it “will pay for direct and accidental loss to your covered auto.” Doc. 45-5 at 24. It limits its liability to the lesser of the actual cash value or the amount necessary to repair or replace the property. Id. at 28; Doc. 53 at 30–32.

The policy does not include a method for determining actual cash value. It provides that the payment will be reduced by a deductible, Doc. 45-5 at 24, and that “[a]n adjustment for depreciation and physical condition will be made in determining actual cash value at the time of loss.” Id. at 28. North Carolina regulations also impose duties on insurers when calculating actual

cash value of totaled vehicles. These will be discussed in detail infra.

1 The Court uses the pagination appended by the CM/ECF system for this and other deposition cites, not the internal pagination used by court reporters transcribing the deposition. To determine the amount it will offer to pay to satisfy the claim, Progressive uses software it licenses from Mitchell International, Inc. called WorkCenter Total-Loss

(WCTL) to generate valuation reports. Doc. 59-1 at ¶¶ 3, 5. Mitchell maintains a database of vehicles recently sold or currently listed for sale and uses these comparator vehicles to estimate the actual cash value of the claimant’s vehicle. Id. at ¶ 5; Doc. 59-2 at ¶ 18. If a comparable vehicle is listed for sale at a dealer that is not known to be a “no- haggle” dealer, Mitchell reduces the vehicle’s list price with a “projected sold adjustment” (PSA) to account for the possibility that the vehicle will sell for less than the

list price.2 Doc. 59-1 at ¶ 6; Doc. 45-7 at 10. All Progressive affiliates use the WCTL Reports as part of the claims adjustment process. See Doc. 53 at 24, 27–29; Doc. 52 at 24–25, 27–29. Progressive also uses other methods to determine actual cash value, but those methods are not at issue here. See Doc. 59-1 at ¶ 16.

To estimate the actual cash value of Ms. Franco’s Jeep, Progressive generated a WCTL Report using the Mitchell software. Doc. 45-7. The report identified four comparable vehicles currently on the market and included their asking price. Id. at 4, 6– 9; Doc. 53 at 49. Because those comparable vehicles were listed for sale but had not yet been sold, the Mitchell software automatically reduced the value of each of those

comparator vehicles using the PSA. Doc. 45-7 at 6–9. Averaging those reduced values

2 For the sake of brevity and ease of reading, the Court has oversimplified some facts that are not particularly relevant to class certification, including those about how the PSA is calculated and other matters. See Doc. 68-2 at ¶ 7 (noting that J.D. Power played a role in designing the WCTL software and PSA); 68-4 at ¶ 27 (same). and applying adjustments and deductions not at issue here yielded the amount of $3,205.65. See id. at 2, 4; Doc. 45-8. Less the deductible, fees, and taxes not at issue

here, that is what Progressive offered and paid Ms. Franco. Docs. 45-8, 45-9; Doc. 59-2 at ¶ 32. Without the PSA deduction, the calculation would have been higher, and Ms. Franco contends she would have and should have received $357.50 more from Progressive for her Jeep. Doc. 47 at 11, 20 n.10. II. Ms. Franco’s Claims and Procedural History Ms. Franco filed this action in March 2024. See Doc. 1. In the operative

complaint, she asserts an individual claim against Progressive Southeastern for breach of contract, Doc. 20 at ¶¶ 72–82, and a claim under the North Carolina Unfair and Deceptive Trade Practices Act, N.C. Gen. Stat. § 75-1.1 et seq. (Chapter 75), against Progressive Casualty on behalf of a putative class. Doc. 20 at ¶¶ 83–103.3 Both claims are based solely on the defendants’ systemic use of the PSA when calculating the actual

cash value of a totaled vehicle; Ms. Franco says that by applying the PSA, Progressive causes claimants to receive less than the actual cash value of their vehicles. Id. at ¶¶ 31– 32, 57, 71, 81, 85–86, 88, 96–98; Doc. 45 at 8–12. She does not seek class certification for her breach of contract claim, and that claim will not be discussed further in this order. Ms. Franco asserts that Progressive’s use of the PSA violates North Carolina’s

total-loss regulation and is thus a per se unfair trade practice under Chapter 75. Doc. 20

3 Early in the litigation, the Court dismissed Ms. Franco’s Chapter 75 claim to the extent it was based on deceptive acts or violations of the North Carolina Unfair Claim Settlement Practices Act, N.C. Gen. Stat. § 58-63-15(11). Doc. 25 at 7. at ¶¶ 84–86; Doc. 45 at 8. In the alternative, she contends that the application of the PSA is an unfair practice because it violates public policy and industry standards. Doc. 20 at

¶¶ 96–97; Doc. 45 at 8. Ms. Franco now moves to certify a class of similarly situated individuals pursuant to Rule 23 of the Federal Rules of Civil Procedure. Doc. 44. She proposes the following class definition: All Progressive insureds of any North Carolina Progressive Company underwriting policies in North Carolina with first-party auto policies issued in the State of North Carolina, who received compensation for the total loss of their vehicles under their first party (comprehensive, collision, and UM/UIM) coverages, and who received a total loss valuation from Progressive generated by the WCTL program which took a deduction/adjustment for “projected sold adjustment” and were paid the amount of the valuation with the “projected sold adjustment.” Id. at 1; Doc. 45 at 6. Both parties filed briefs with evidentiary support. Docs. 45, 47, 59, 61, 62, 64. Upon the Court’s order, Doc. 65, Ms.

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