Garcia v. United of Omaha Life Insurance Company

CourtDistrict Court, D. Rhode Island
DecidedJuly 10, 2020
Docket1:20-cv-00043
StatusUnknown

This text of Garcia v. United of Omaha Life Insurance Company (Garcia v. United of Omaha Life Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia v. United of Omaha Life Insurance Company, (D.R.I. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

) HECTOR M. GARCIA, SR., ) Individually, and in his Capacity as ) Administrator of the ESTATE OF ) MARTA J. GARCIA, ) ) Plaintiff, ) ) v. ) C.A. No. 1:20-CV-00043-MSM-PAS ) UNITED OF OMAHA LIFE ) INSURANCE COMPANY a/k/a ) MUTUAL OF OMAHA INSURANCE ) COMPANY, ALIAS; THE BENN ) AGENCY, ALIAS; AND DEBBIE ) BENN, ALIAS, ) ) Defendants. )

MEMORANDUM AND ORDER

Mary S. McElroy, United States District Judge.

This matter comes before the Court on the Motion to Dismiss, pursuant to Fed. R. Civ. P. 12(b)(6), of The Benn Agency and Debbie Benn (collectively “the Benn defendants”). (ECF No. 16.) The Court must consider whether the plaintiff’s Complaint plausibly states a claim for breach of contract and breach of fiduciary duty against the Benn defendants. For the following reasons, the Court provisionally GRANTS the Benn defendants’ Motion to Dismiss. I. BACKGROUND

The following facts are as alleged in the plaintiff’s Complaint. On or about June 24, 2015, the plaintiff’s decedent, Marta J. Garcia, applied for and purchased a life insurance policy from the defendant United of Omaha Life Insurance Company a/k/a Mutual of Omaha Insurance Company (“Omaha”). (ECF No. 1-1 ¶ 8.) The agent responsible for securing the life insurance policy was Debbie Benn, who “held herself out as an agent of Omaha and [The Benn Agency].” ¶¶ 4, 8. Mrs. Garcia was not proficient in English. ¶ 9. Ms. Benn completed the life insurance application and had Mrs. Garcia sign the application. ¶ 10. Mrs. Garcia did not understand that some of the representations Ms. Benn made were

inaccurate. ¶ 11. On or about June 24, 2015, Mrs. Garcia authorized Omaha to debit her bank account automatically each month, as a premium payment for the life insurance policy. ¶ 12. The plaintiff was listed as the primary beneficiary of the life insurance policy and subject to payment of $181,000. ¶¶ 13-14. On or about February 19, 2016, Mrs. Garcia died. ¶ 15. The plaintiff sought payment under the policy, but Omaha

refused to make payment. ¶ 16. Omaha informed the plaintiff that the life insurance policy had been rescinded and offered to refund the premiums paid. ¶ 17. The plaintiff filed suit alleging claims of breach of contract and “breach of covenant of good faith and fair dealing in violation of fiduciary duties” against all defendants. The plaintiff does not distinguish his claims against the Benn defendants from those against Omaha; rather, both claims are asserted generally against “defendants.”

II. MOTION TO DISMISS STANDARD On a Rule 12(b)(6) motion, the Court assesses the sufficiency of the plaintiff’s factual allegations in a two-step process. , 640 F.3d 1, 7, 11-13 (1st Cir. 2011). “Step one: isolate and ignore statements in the complaint that simply offer legal labels and conclusions or merely rehash cause-of- action elements.” , 699 F.3d 50, 55 (1st Cir. 2012). “Step two: take the complaint’s well-pled ( non-conclusory, non-

speculative) facts as true, drawing all reasonable inferences in the pleader’s favor, and see if they plausibly narrate a claim for relief.” “The relevant question … in assessing plausibility is not whether the complaint makes any particular factual allegations but, rather, whether ‘the complaint warrant[s] dismissal because it failed to render plaintiffs’ entitlement to relief plausible.” , 711 F.3d 49, 55 (1st Cir. 2013) (quoting

, 550 U.S. 544, 569 n.14 (2007)). III. DISCUSSION A. The Question of Diversity of Citizenship

As a preliminary matter, the Court must consider the jurisdictional question of diversity of citizenship. Omaha removed this action from Rhode Island Superior Court on the grounds of diversity jurisdiction because the plaintiff and Omaha are citizens of different states and the amount in controversy exceeds $75,000. (ECF No. 1.) The Benn defendants, however, reside in Rhode Island, like the plaintiff. A federal court generally only has diversity jurisdiction when complete diversity exists between the parties, that is, when no plaintiff is a citizen of the same state as any defendant. 28 U.S.C. § 1332(a).

But Omaha posits that the Benn defendants have been “fraudulently joined.” (ECF No. 1 at 3.) If a court “has determined that a party has been fraudulently joined, it proceeds to analyze jurisdiction without reference to the fraudulently joined party.” , 414 F. Supp. 2d 134, 137 (D.R.I. 2006). Application of the doctrine of “fraudulent joinder” need not require a finding of “outright fraud”; rather, “in most cases fraudulent joinder involves a claim against an in-state defendant that simply has no chance of success, whatever the plaintiff's

motives.” , 210 F. Supp. 2d 62, 68 (D.R.I. 2002) (quoting , 959 F.2d 69, 73 (7th Cir.1992)); , 414 F. Supp. 2d at 137 (“Because fraudulent joinder describes any improper joinder, a defendant need not prove that the plaintiff intended to mislead or deceive in order to sustain its burden.”). In such instances, fraudulent joinder will apply when “there is no possibility, based on the pleadings, that the plaintiff can state a cause of action

against the non-diverse defendant in state court.” , 210 F. Supp. 2d 62, 67 (D.R.I. 2002) (quoting , 178 F. Supp. 2d 1, 5 (D. Mass. 2001)). For the reasons discussed below, the Court finds that the pleadings, as written, do not state a claim against the Benn defendants and thus the application of the doctrine of “fraudulent joinder” is appropriate under these circumstances. Diversity of citizenship exists between the plaintiff and the remaining defendant, Omaha, and the amount in controversy is sufficient to confer jurisdiction upon this Court. 28 U.S.C. § 1332(a).

B. The Plaintiff’s Claims Against the Benn Defendants

1. Breach of Contract

The Benn defendants argue that they cannot be liable for breach of the life insurance contract because they were not a party to that contract. The Court agrees. While the Benn defendants were agents for Omaha, “an agent is not ordinarily liable for his principal’s breach of contract … and where an agent acts on behalf of a disclosed principal, the agent will not be personally liable for a breach of contract, unless there is clear and explicit evidence of the agent’s intention to be bound.” , 474 F. Supp. 2d 298, 312 (D.R.I. 2007) (internal citations omitted). , 119 R.I. 307, 315, 377 A.2d 237

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