GEICO Marine Insurance Company v. Mandel

CourtDistrict Court, E.D. New York
DecidedMarch 10, 2023
Docket2:19-cv-03107
StatusUnknown

This text of GEICO Marine Insurance Company v. Mandel (GEICO Marine Insurance Company v. Mandel) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GEICO Marine Insurance Company v. Mandel, (E.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK X GEICO Marine Insurance Company,

Plaintiff, MEMORANDUM AND ORDER v. FILED 19-CV-3107 (GRB)(AYS) CLERK Lee Mandel, 3:56 pm, Mar 10, 2023

Defendant. U.S. DISTRICT COURT X EASTERN DISTRICT OF NEW YORK LONG ISLAND OFFICE Lee Mandel,

Counter Claimant,

v.

GEICO Marine Insurance Company

Counter Defendant. X

GARY R. BROWN, United States District Judge:

GEICO Marine Insurance Company commenced this insurance coverage action against Lee Mandel seeking a declaratory judgment as to the rights and obligations of the parties under two yacht insurance policies. Pending before the Court are cross-motions for summary judgment. For the reasons set forth below, Mandel’s motion is DENIED and GEICO’s motion is GRANTED in its entirety. Facts and Procedural History

Based on this Court’s opinion in GEICO Marine Ins. Co. v. Mandel, No. 19-CV- 3107(SJF)(AKT), 2020 WL 6318948, at *3 (E.D.N.Y. Sept. 18, 2020), report and recommendation adopted, No. 19-CV-3107(SJF)(AKT), 2020 WL 5939186 (E.D.N.Y. Oct. 7, 2020), the parties’ Rule 56.1 Statements, and review of the evidence submitted, the material undisputed facts include the following: Lee Mandel was the owner of a 52’ SeaRay sedan bridge-model seafaring vessel. 2020 WL 6318948, at *3. GEICO issued Mandel two yacht insurance policies for 2015-16 and 2016-

17. Id. Both policies required that, “With respect to any claim or loss to insured property, the action must begin within one year of the date of loss or damage.” Id. In December 2015, Mandel submitted a claim for damage to the starboard, i.e., right-side, engine. GEICO approved piecemeal repairs of approximately $92,400. Id. In July 2016, Mandel submitted a supplemental claim for damages caused by a crack in the engine cylinder. Id. In August 2016, Mandel submitted a claim for damages to the port, i.e., left-side, engine. Id. Afterward, the starboard engine began emitting blue-white smoke. Id. GEICO inspected the vessel in September and November 2016 to investigate Mandel’s claims. Id. In December 2016, Mandel removed and replaced the starboard and port engines. Id. In February 2017, GEICO gave Mandel a supplemental and final payment of approximately $17,400

for damage to the starboard engine. Id. GEICO inspected the vessel once again in November 2017. Id. GEICO’s February 2018 report declined to pay Mandel the replacement cost of the engine because “the decision to proceed with the replacement of Mr. Mandel’s engines was made at his direction and not in accordance with the previous settlements issued” since “replacements of both engines and auxiliary components . . . do not represent, as set forth by the policy, a reasonable cost of repair, [but] instead constitute betterment.” Id. at *3-4. Later that month, GEICO paid Mandel approximately $23,200 for damage to the port engine. Id. at *4. Over a year later, in April 2019, Mandel renewed his demand for the cost of replacing the starboard and port engines – approximately $213,500 after payments received – and advised that he would pursue litigation if not paid. Id. In response, GEICO Marine Insurance Company commenced this insurance coverage

action in May 2019 seeking a declaratory judgment that Mandel is not entitled to coverage for the claimed losses. DE 1. The complaint asserts three causes of action based on the insurance policies’ exclusions (Counts I and II) and the one-year limitation for bringing legal action (Count III). In July 2019, Mandel filed a counterclaim, alleging GEICO breached the insurance policy and acted in “bad faith”1 by (1) paying less than what the insurance policies provide; (2) negligently and/or inadequately investigating his claims; and (3) instituting this legal action instead of pursuing the appraisal process. See DE 7, ¶¶ 91-104. The following day, Mandel requested an appraisal under the policies, which state, “If you have met the requirements and conditions of the policy, and if the amount of a covered loss is still in dispute, you or [GEICO] may demand an appraisal of such loss.” 2020 WL 6318948 at *4; DE 21-2, ¶ 13; DE 22-3, ¶ 13. GEICO denied

the appraisal request, taking the position that the appraisal process was inapplicable since there was a dispute as to the existence of coverage – not the amount of covered loss. 2020 WL 6318948 at *4. In December 2019, GEICO moved for partial summary judgment on its third cause of action regarding the policies’ one-year limitation, and on Mandel’s counterclaims for breach of contract and “bad faith.” Id. at *5. The Court held that Mandel’s breach of contract counterclaim based on GEICO’s failure to indemnify him for the cost of replacing the engines accrued in February 2018 when GEICO advised Mandel that it declined such payment, and that his claim

1 The Court construed the “bad faith” claim as a claim for breach of the implied covenant of good faith and fair dealing. 2020 WL 6318948 at *9. based on negligent and/or inadequate investigation accrued when the last vessel inspection occurred in November 2017. Id. at *9. Since the breach of contract counterclaim was filed more than a year after liability accrued, it was time-barred under the policies’ one-year time limitation provision. Id. at *9. Thus, the Court granted GEICO’s motion for partial summary judgment on

Count III. As to the claim for the breach of the implied covenant of good faith and fair dealing, the Court held that this claim was also time-barred with respect to the allegedly negligent and/or inadequate investigation and failure to promptly conclude its investigation. Id. at *10. However, Mandel’s claim that GEICO breached the implied covenant of good faith and fair dealing by commencing the instant action was not time-barred because GEICO filed this lawsuit in May 2019 and the counterclaim was filed less than a year later in July. Id. at *10. Mandel now seeks summary judgment on his sole remaining counterclaim for breach of the implied covenant of good faith and fair dealing based on GEICO’s commencement of the instant action. DE 21-1. GEICO seeks summary judgment dismissing Mandel’s sole remaining

counterclaim and a declaration that GEICO has no further legal obligations as to the vessel’s starboard and port engines. DE 22-1 at 2. Standard of Review These cross-motions for summary judgment are decided under the oft-repeated and well understood standard for review of such matters, as discussed in Bartels v. Inc. Vill. of Lloyd Harbor, 97 F. Supp. 3d 198, 211 (E.D.N.Y. 2015), aff’d sub nom. Bartels v. Schwarz, 643 F. App’x 54 (2d Cir. 2016), which discussion is incorporated by reference herein. Discussion “A covenant of good faith and fair dealing is implicit in every insurance contract and encompasses not only any promise that a reasonable promisee would understand to be included, but also that ‘a reasonable insured would understand that the insurer promises to investigate in

good faith and pay covered claims.’” Roemer v. Allstate Indem. Ins. Co., 163 A.D.3d 1324, 1325– 26 (2018) (quoting New York Univ. v Continental Ins. Co., 87 NY2d 308, 318 (1995)). A prima facie case of bad faith requires showing a “gross disregard” of the insured’s interests. Id. (citing Pavia v State Farm Mut. Auto. Ins. Co., 82 NY2d 445, 453 (1993)). “[T]here remains a strong presumption in New York against a finding of bad faith liability by an insurer . . . [which] can be rebutted only by evidence establishing that the insurer’s refusal to defend was based on ‘more than an arguable difference of opinion’ and exhibited ‘a gross disregard for its policy obligations.’” Hugo Boss Fashions, Inc. v. Fed. Ins. Co., 252 F.3d 608, 624–25 (2d Cir.

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GEICO Marine Insurance Company v. Mandel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/geico-marine-insurance-company-v-mandel-nyed-2023.