General Security Indemnity Company of Arizona v. Gerald Jones Ford, LLC

CourtCourt of Appeals of Georgia
DecidedJune 18, 2024
DocketA24A0477
StatusPublished

This text of General Security Indemnity Company of Arizona v. Gerald Jones Ford, LLC (General Security Indemnity Company of Arizona v. Gerald Jones Ford, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
General Security Indemnity Company of Arizona v. Gerald Jones Ford, LLC, (Ga. Ct. App. 2024).

Opinion

FIFTH DIVISION MERCIER, C. J., MCFADDEN, P. J., and RICKMAN, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

June 18, 2024

In the Court of Appeals of Georgia A24A0477. GENERAL SECURITY INDEMNITY COMPANY OF ARIZONA v. GERALD JONES FORD, LLC.

MERCIER, Chief Judge.

Jerquavius Berry purchased a vehicle from Gerald Jones Ford, LLC, (“the

Dealership”), and within a week he got into a collision while fleeing police officers in

Virginia and the vehicle sustained a total loss. After Berry failed to pay the remainder

of the financed amount for the vehicle and General Security Indemnity Company of

Arizona (“General Security”) denied the Dealership’s insurance claim, the

Dealership filed the underlying lawsuit against General Security and Berry, seeking,

inter alia, a declaratory judgment regarding General Security’s insurance coverage.1

1 The Dealership initially filed suit against North American Risk Services, Inc., but later substituted General Security for North American by consent. The Dealership and General Security filed cross-motions for summary judgment, and

the trial court granted the Dealership’s motion and denied General Security’s

motion.2 General Security filed this appeal, which turns on whether a denied claim

renders an insurance policy “invalid.” For the following reasons, we find that it does

not and reverse the trial court.

“On appeal from the grant of summary judgment this Court conducts a de novo

review of the evidence to determine whether there is a genuine issue of material fact

and whether the undisputed facts, viewed in the light most favorable to the nonmoving

party, warrant judgment as a matter of law.” Auto-Owners Ins. Co. v. Neisler, 334 Ga.

App. 284, 284 n. 1 (779 SE2d 55) (2015) (citation and punctuation omitted); see also

OCGA § 9-11-56 (c). That being said, the facts are undisputed. Berry paid a $4,000

down payment and financed the remainder of the price, $23,408.52, in order to

purchase the vehicle from the Dealership on January 23, 2020. Exeter Finance LLC

(“Exeter”) approved the finance terms and purchased the note from the Dealership.

In order to purchase the vehicle, Berry presented evidence of an insurance policy with

Falls Lake National Insurance Company (“Falls Lake”) to the Dealership.

2 Berry is not a party to this appeal. 2 Three days after he purchased the vehicle, while fleeing police in Virginia,

Berry crashed the vehicle, causing a total loss. Berry was later found guilty of violating

Virginia Criminal Code § 46.2-817.

Exeter attempted to contact Berry in order to complete the loan validation

process, but Berry did not respond, and he failed to make his payments. Thereafter,

Exeter rejected the note and returned it to the Dealership.

The Dealership made a claim for the vehicle under Berry’s Falls Lake insurance

policy. The Falls Lake policy provided that claims for Berry’s property damage were

excluded from coverage “[w]hile [Berry] or anyone driving with [his] permission is

using [his] insured auto in an illegal trade or transportation or fleeing a law

enforcement agency.” As Berry was fleeing police when the vehicle sustained a total

loss, Falls Lake denied the claim.

Prior to selling Berry the automobile, the Dealership obtained an automobile

physical damage insurance policy from General Security. The Dealership submitted

a claim for Berry’s vehicle to General Security, but General Security denied the claim,

stating that the loss did not fall within the policy’s coverage.

3 Thereafter, the Dealership filed the underlying declaratory judgment action

against General Security. This appeal followed the grant of summary judgment to the

Dealership.

The Dealership’s insurance policy with General Security provided coverage for

insured vehicles until the vehicle was sold or leased by the Dealership. However, the

policy also contained a spot delivery extension, which provided

coverage for [the Dealership’s] financial interest in a covered vehicle sold by [the Dealership] and delivered to the purchaser, but for which [the Dealership] [has] not been fully paid, and where the purchaser provided [the Dealership] evidence of insurance prior to delivery, which proved to be invalid at the time of loss to the covered vehicle.3

(Emphasis in original). Here, there is no dispute that the Dealership sold the vehicle

to Berry, and before it provided delivery to Berry, he presented the Dealership with

evidence of insurance. Further, there is no dispute that the Dealership was not fully

paid. The only dispute at issue is whether Berry’s Falls Lake policy was invalid at the

time of the loss.

3 “Evidence of insurance” is defined in the General Security policy as: “a binder, policy, insurance certificate or other written documentation that has been issued by an authorized agent or representative of the insurance company covering such vehicle.” (Emphasis in original). 4 General Security argues that the trial court incorrectly interpreted the term

“invalid” in its insurance policy, and that the Falls Lake policy was valid, but merely

excluded coverage for the incident as Berry was fleeing police at the time of the crash.

In our interpretation of the insurance policy, we are reminded that “[a]n insurance

policy is simply a contract, the provisions of which should be construed as any other

type of contract.” American Empire Surplus Lines Ins. Co. v. Hathaway Dev. Co., 288

Ga. 749, 750 (707 SE2d 369) (2011) (citation and punctuation omitted). Construction

of a contract, and thus an insurance policy, is a question of law for the court. See id.

In our analysis, we undertake “a three-step process in the construction of the contract,

the first of which is to determine if the instrument’s language is clear and

unambiguous. If the language is unambiguous, the court simply enforces the contract

according to the terms, and looks to the contract alone for the meaning.” Id. (citation

and punctuation omitted). Further,

[w]ords generally bear their usual and common signification; but technical words, words of art, or words used in a particular trade or business will be construed, generally, to be used in reference to this peculiar meaning. The local usage or understanding of a word may be proved in order to arrive at the meaning intended by the parties[.]

5 OCGA § 13-2-2 (2).

Here, the General Security policy did not define the term “invalid.” When a

contract term is not expressly defined, we look to the usual and common meaning of

the term. Taylor Morrison Svcs. v. HDI-Gerling American Ins. Co., 293 Ga. 456, 465 (2)

(746 SE2d 587) (2013). In Holmes v. Clear Channel Outdoor, 298 Ga. App. 178 (679

SE2d 745) (2009), we looked to a dictionary for the meaning of the term “invalidate”

and found the definition: “to render of no force or effect.” Id. at 181 (1) (citing

Webster’s New International Dictionary, p. 1305 (2d ed. 1961))4. Similarly, Black’s

Law Dictionary defines “invalid contract” as “[a]n agreement that is either void or

voidable.” Black’s Law Dictionary (11th ed. 2019). While a dictionary is a useful tool

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Related

Holmes v. Clear Channel Outdoor, Inc.
679 S.E.2d 745 (Court of Appeals of Georgia, 2009)
Reed v. Auto-Owners Insurance
667 S.E.2d 90 (Supreme Court of Georgia, 2008)
American Empire Surplus Lines Insurance v. Hathaway Development Co.
707 S.E.2d 369 (Supreme Court of Georgia, 2011)
Archer Western Contractors, Ltd. v. Estate of Pitts
735 S.E.2d 772 (Supreme Court of Georgia, 2012)
Taylor Morrison Services, Inc. v. HDI-Gerling America Insurance
746 S.E.2d 587 (Supreme Court of Georgia, 2013)
Auto-Owners Insurance v. Neisler
779 S.E.2d 55 (Court of Appeals of Georgia, 2015)

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General Security Indemnity Company of Arizona v. Gerald Jones Ford, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/general-security-indemnity-company-of-arizona-v-gerald-jones-ford-llc-gactapp-2024.