Fuselier v. Progressive County Mutual Insurance Co

CourtDistrict Court, W.D. Louisiana
DecidedNovember 29, 2021
Docket2:20-cv-01250
StatusUnknown

This text of Fuselier v. Progressive County Mutual Insurance Co (Fuselier v. Progressive County Mutual Insurance Co) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fuselier v. Progressive County Mutual Insurance Co, (W.D. La. 2021).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION

SILTON R FUSELIER JR CASE NO. 2:20-CV-01250

VERSUS JUDGE JAMES D. CAIN, JR.

PROGRESSIVE COUNTY MUTUAL MAGISTRATE JUDGE KAY INSURANCE CO

MEMORANDUM RULING

Before the court is a Motion for Summary Judgment filed by defendant Progressive County Mutual Insurance Co. (“Progressive”) [Doc. 10]. Defendant asserts that they are entitled to a judgment as a matter of law dismissing plaintiff Stilton R. Fuselier’s claims that Progressive’s policy provides $1 million of underinsured motorist coverage. Defendant also asks this court to find that Texas law applies to the Progressive policy number 00190556-0, the policy at issue in this case. Plaintiff, Stilton R. Fuselier, opposes the Motion for Summary Judgment [Doc. 14]. FACTUAL STATEMENT This suit arises from a motor vehicle accident that took place on October 8, 2019. In his petition for damages, Mr. Fuselier states he was traveling eastbound on Interstate 10 near Vinton, Louisiana when an unidentified driver swerved in front of him.1 Mr. Fuselier took evasive action to avoid colliding with the unidentified driver and came to rest in a ditch located on the south of Interstate 10 without having come into contact with any other

1 Doc. 1-4. State Court Petition. motor vehicle.2 As a result of the accident, Mr. Fuselier claims to have suffered serious injuries requiring extensive treatment and claims to have incurred over $1 million in medical expenses.3

Prior to the accident, Mr. Fuselier obtained a Progressive policy to insure the Ford F-450 that is at issue in this case.4 On December 26, 2018, the Application for Insurance (“the Application”) was submitted to Progressive and Mr. Fuselier’s address was listed as 8110 Sage Road, Orange, Texas 77632.5 The Application requested underinsured motorist coverage in the amount of $30,000 per person and $60,000 per accident.6 Additionally, the

Application listed the garaging location of the insured vehicle as 77632 Orange, Texas.7 Pursuant to the Application, Progressive delivered policy number 00190556-0 to Mr. Fuselier.8 Mr. Fuselier asserts that he has always been a Louisiana resident and that the insured vehicle has always been licensed, registered, and titled in Louisiana.9 Mr. Fuselier further

explains that he was operating his vehicle in Texas for business until April 2019, at which time he operated the vehicle almost exclusively in Louisiana.10 On April 6, 2019, Mr. Fuselier changed his mailing address from the Texas address to 3200 West Wood Road,

2 Doc. 14-1. 3 Doc. 1-4. State Court Petition. 4 Doc. 14- 1. 5 Doc. 10-2. 6 Id. 7 Id. 8 Id. 9 Doc. 14-1. 10 Id. Lot 57, Westlake, Louisiana 70669.11 Progressive sent notices and premium invoices to Mr. Fuselier’s Louisiana address prior to the accident.12 Progressive asserts that at no time did Mr. Fuselier notify Progressive of any change

in circumstances, other than the change in mailing address.13 However, Mr. Fuselier argues that on May 13, 2019, he received a renewal notice from Progressive that acknowledges the vehicle at issue was now garaged in Westlake, Louisiana.14 Defendants now move for summary judgment to dismiss the claims that Mr. Fuselier is entitled to coverage in the amount of $1 million and ask this Court to find that Texas law

applies to this policy. SUMMARY JUDGMENT STANDARD A court should grant a motion for summary judgment when the movant shows “that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56. The party moving for summary judgment is initially

responsible for identifying portions of pleadings and discovery that show the lack of a genuine issue of material fact. Tubacex, Inc. v. M/V Risan, 45 F.3d 951, 954 (5th Cir. 1995). The court must deny the motion for summary judgment if the movant fails to meet this burden. Id. If the movant makes this showing, however, the burden then shifts to the non-

moving party to “set forth specific facts showing that there is a genuine issue for trial.”

11 Doc. 10-2. 12 Doc. 14-1. 13 Doc. 10-1. 14 Doc. 14-5. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986) (quotations omitted). This requires more than mere allegations or denials of the adverse party's pleadings. Instead, the nonmovant must submit “significant probative evidence” in support of his claim. State

Farm Life Ins. Co. v. Gutterman, 896 F.2d 116, 118 (5th Cir. 1990). “If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted.” Anderson, 477 U.S. at 249 (citations omitted). A court may not make credibility determinations or weigh the evidence in ruling on a motion for summary judgment. Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S.

133, 150 (2000). The court is also required to view all evidence in the light most favorable to the non-moving party and draw all reasonable inferences in that party’s favor. Clift v. Clift, 210 F.3d 268, 270 (5th Cir. 2000). Under this standard, a genuine issue of material fact exists if a reasonable trier of fact could render a verdict for the nonmoving party. Brumfield v. Hollins, 551 F.3d 322, 326 (5th Cir. 2008).

LAW & APPLICATION

A. Choice of Law

Here, a substantive conflict exists between relevant Louisiana and Texas laws. The two conflicts most relevant to this motion are the form requirements to waive underinsured motorist limits and coverage when an unidentified vehicle causes an accident. In Louisiana, if underinsured motorist limits are selected that are lower than the liability limits, a valid waiver selection form must be executed. Duncan v. U.S.A.A. Ins. Co., 950 So.2d 554, 551 (La. 2006). In contrast, Texas does not require the underinsured motorist limits to match the liability limits for bodily injury. TX Ins. Code Ann. Art. 1952.105. Additionally, Louisiana does not require physical contact to recover under an

underinsured motorist policy if the insured can prove “by an independent and disinterested witness, that the injury was the result of the action of the driver of another vehicle whose identity is unknown. La. R. S. 22:1406(D)(1)(f). However, in Texas, there is no underinsured motorist coverage if an unidentified vehicle runs an insured off the road, but does not actually hit the insured’s vehicle. Goen v. Trinity Universal Ins. Co. of Kansas,

715 S.W. 2nd 124, 125 (Tex. App. 1986). The Court must resolve this conflict by determining which state’s law applies to the underinsured motorist coverage under the insurance policy. For contractual claims, Louisiana courts look to the following factors in a choice of law analysis:

(1) the pertinent contacts of each state to the parties and the transaction, including the place of negotiation, formation, and performance of the contract, and the place of domicile, habitual residence, or business of the parties; (2) the nature, type, and purpose of the contract; and (3) the policies referred to in Article 3515, as well as the policies of facilitating the orderly planning of transactions, of promoting multistate commercial intercourse, and of protecting one party from undue imposition by the other.

La. Civ. Code art. 3537.

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