Gochev v. First American Property & Casualty Insurance Company

CourtDistrict Court, W.D. Washington
DecidedJanuary 19, 2024
Docket2:22-cv-00159
StatusUnknown

This text of Gochev v. First American Property & Casualty Insurance Company (Gochev v. First American Property & Casualty Insurance Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gochev v. First American Property & Casualty Insurance Company, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 HRISTO GOCHEV, et al., 9 Plaintiffs, Case No. C22-159-MLP 10 v. ORDER 11 FIRST AMERICAN PROPERTY AND CASUALTY INSURANCE CO., 12 Defendant. 13

14 I. INTRODUCTION 15 This matter is before the Court on: (1) Plaintiff Hristo “Chris” Gochev’s (“Plaintiff”) 16 “Motion Regarding Attorney Fees and Costs and for Enhanced Damages under the Insurance 17 Fair Conduct Act” (“IFCA”) (“Plaintiff’s Fees Motion”) (Pl.’s Fees Mot. (dkt. # 82)); (2) 18 Plaintiff’s “Motion to Modify Judgment” (Pl.’s Mot. (dkt. # 86)); and (3) Defendant First 19 American Property & Casualty Insurance Company’s (“First American”) “Rule 50(b) Motion for 20 Judgment as a Matter of Law” (“First American’s Motion”) (Def.’s Mot. (dkt. # 88)).1 21

22 1 First American notes its motion is brought pursuant to Fed R. Civ. P. 50(b) and Fed. R. Civ. P. 59(a). (See Def.’s Mot. at 1.) But it is unclear whether First American seeks a new trial as it did not provide any 23 argument pursuant to Rule 59(a) (see id.) and confusingly submits later in its motion that it is brought pursuant to Rule 50(b) and Fed. R. Civ. P. 59(e). (See id. at 3.) First American only provided legal 1 Having considered the parties’ submissions, the balance of the record, and the governing 2 law: (1) Plaintiff’s Fees Motion (dkt. # 82) is GRANTED in part and DENIED in part; (2) 3 Plaintiff’s Motion to Modify Judgment (dkt. # 86) is GRANTED in part and DENIED in part; 4 and (3) First American’s Motion (dkt. # 88) is DENIED, as further explained below.

5 II. BACKGROUND 6 The Court conducted a jury trial in this matter on Plaintiff’s claims against First 7 American for insurer bad faith, violation of the Washington Consumer Protection Act (“CPA”), 8 and violation of IFCA. (See dkt. ## 58, 65, 70.) The Court has previously detailed the 9 background of this case in its previous Order on summary judgment. (See dkt. # 34 at 2-8.) 10 Relevant to the parties’ motions, on December 7, 2021, Plaintiff’s counsel issued an 11 IFCA notice of claim to First American alleging First American unreasonably delayed claim 12 payment. (Monroe Decl., Ex. 5 (dkt. # 22-5); First Brooks Decl. (dkt. # 24) at ¶ 3.) The issued 13 IFCA notice provides in part that: 14 Mr. Gochev and Kaiser Enterprises reported a loss to First American earlier this year. Shortly after the claim was reported, First American started causing delay, 15 and refused to clarify what was covered and what was not covered. Then, First American demanded Mr. Gochev undergo an unnecessary examination under oath, 16 and only after that did they state what amount was covered and offered what was clearly from the beginning a covered loss. 17 . . . 18 It is clear from the fact of this case that [First American’s] handling of this claim 19 has led to damages that should never have occurred had this file been properly handled from the start. From the beginning, you have delayed the investigation of 20 the claim, failed to promptly act, and failed to communicate with your insured.

21 You also delayed payment unnecessarily by not promptly adjusting and paying what was owed to your insured. Additionally, you have put your own interest ahead 22 of the interest of your insured.

23 standards pursuant to Rule 59(e) to alter or amend the judgment entered in this case. (See id. at 2-3.) Nonetheless, to the extent First American’s Motion can be construed to request a new trial, that request is denied for reasons explained below. 1 (Monroe Decl., Ex. 5 at 1-2.) 2 On August 14, 2023, on summary judgment, First American argued that Plaintiff’s IFCA 3 claim should be dismissed because: (1) Plaintiff failed to allege a wrongful denial or 4 underpayment of benefits as required for an IFCA claim; and (2) Plaintiffs’ IFCA notice was

5 ineffective. (Def.’s Summ. J. Mot. (dkt. # 20) at 13-14.) Specifically, First American argued that 6 Plaintiff’s IFCA claim failed as a matter of law because IFCA does not create an independent 7 cause of action solely for violations of the Washington Administrative Code. (Id. at 13 (citing 8 Perez-Crisantos v. State Farm Fire & Cas. Co., 187 Wn.2d 669, 680 (Wash. 2017).) First 9 American additionally argued that Plaintiff’s 20-day IFCA notice was ineffective because it 10 failed to set forth what First American could do to avoid suit or fix the alleged wrongful denial or 11 underpayment of benefits. (Id. at 13-14.) 12 On September 27, 2023, this Court denied First American’s challenge to the IFCA claim 13 on summary judgment. (Dkt. # 34 at 17-19.) The Court noted that Plaintiff’s IFCA notice clearly 14 outlined the basis for Plaintiff’s complaints with First American’s delay in investigating and

15 adjusting his insurance claim in his written notice, as required by RCW 48.30.015(8), prior to 16 filing an IFCA action.2 (Id. at 19.) In addition—based on authority provided by Plaintiff (see dkt. 17 # 23 at 9-11) and left unrebutted by First American (see dkt. # 29 at 3-4)—the Court found that 18 this District has recognized that “a refusal to pay a demand for coverage reasonably promptly is 19 an unreasonable denial of benefits, even if only temporary” for IFCA claims. (Dkt. # 34 at 19 20 (quoting Taladay v. Metro. Grp. Prop. & Cas. Ins. Co., 2016 WL 3681469, at *2 (W.D. Wash. 21

22 2 The IFCA notice requirement only requires a first-party claimant to “provide written notice of the basis for the cause of action to the insurer and office of the insurance commissioner” twenty days prior to filing 23 an IFCA action. RCW 48.30.015(8)(a). If the insurer fails to resolve the basis of the action, the claimant may bring their action without further notice. RCW 48.30.015(8)(b). 1 July 6, 2016)).) The Court therefore concluded that a genuine issue of material existed as to 2 whether First American acted unreasonably in handling Plaintiff’s claim for the alleged IFCA 3 claim, distinct from Plaintiff’s alleged insurance regulatory violations. (Id.) 4 On October 11, 2023, the parties submitted agreed and disputed jury instructions prior to

5 trial. (Dkt. # 50.) As part of the agreed submitted instructions, the parties provided instructions 6 on “Violation of [IFCA]” and “Unreasonable Delay in Payment.” (See id. at 3.) The “Violation 7 of [IFCA]” instruction provided the elements for the jury to find a violation of IFCA pursuant to 8 a modified version of Washington Pattern Civil Jury Instruction 320.06.01.3 (Id. at 26.) The 9 “Unreasonable Delay in Payment” instruction instructed that an unreasonable delay in payment 10 can constitute an unreasonable denial of benefits based on Taladay and other authority from this 11 District. (Id. at 3, 29-30.) 12 On October 16, 2023, the first day of trial, Plaintiff testified as to damages he incurred 13 based on the storage costs of property he was asked by First American to maintain for its 14 examination. (See Day 1 Trial Tr. (dkt. # 103) at 157:7-159:1.) As to storage costs, Plaintiff

15 testified: 16 17 3 The parties’ IFCA instruction specifically provides: 18 Gochev and Kaiser Trucking claim that First American violated the [IFCA]. To prove that 19 claim, Gochev & Kaiser Trucking, LLC has [sic] the burden of proving each of the following propositions: 20 1. First American Property and Casualty unreasonably denied a claim for coverage or payment of benefits, 21

2.

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Gochev v. First American Property & Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gochev-v-first-american-property-casualty-insurance-company-wawd-2024.