Goldman v. Vigilant Insurance Company

CourtDistrict Court, D. Nevada
DecidedSeptember 29, 2022
Docket2:19-cv-02227
StatusUnknown

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

Bluebook
Goldman v. Vigilant Insurance Company, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Robert L. Goldman, Case No.: 2:19-cv-02227-JAD-BNW

4 Plaintiff Order Granting Vigilant’s Motion for 5 v. Summary Judgment in Part and Dismissing Action without Prejudice 6 Vigilant Insurance Company, [ECF No. 33] 7 Defendant

8 This is an insurance-coverage dispute related to a water leak at a property that Robert 9 Goldman rented out to his company for business use. During the adjusting process, Goldman 10 took the position that Vigilant Insurance Company’s bad-faith claim-handling practices rendered 11 it equitably estopped from enforcing its rights under the policy to require him to submit to an 12 examination under oath and provide additional documentation of his loss. And although the 13 policy contains a “legal action against us” clause that precludes the insured from bringing suit 14 without having complied with all policy conditions, Goldman filed this action without first 15 satisfying those requirements. Vigilant moves for summary judgment, arguing that Goldman’s 16 failure to comply with myriad policy conditions voids coverage and bars this suit. I find that 17 there is no genuine dispute that Goldman refused to comply with the examination-under-oath 18 provision and that Vigilant did not waive that right nor was it equitably estopped from enforcing 19 it, and the “legal action against us” clause prevented him from bringing this suit until he 20 complied. So I grant Vigilant’s motion for summary judgment on this basis and dismiss this suit 21 without prejudice. 22 23 1 Background1 2 I. Insured property 3 Vigilant2 insured a property in Las Vegas owned by Goldman that has at least two 4 structures: a main house and a guest house.3 Goldman, who lives in California, let the property

5 out to his company Cels Enterprises to use for storage and to house employees during local 6 tradeshows.4 The lease agreement began in 2008 and was set to expire in 2017.5 7 II. The Vigilant insurance policy 8 Goldman’s homeowners’ policy with Vigilant provided (1) property-damage coverage 9 for “all risk of physical loss” and (2) loss-of-use coverage for the property’s “fair rental value” if 10 “a covered loss ma[de] part of [the] house . . . [that] [Goldman] usually rent[ed] to others 11 uninhabitable.”6 The policy further recounts that Vigilant was providing the coverage “in return 12 for [Goldman’s] premium and compliance with the policy conditions.”7 13 Two of those conditions are the focus of this motion: the examination-under-oath 14 condition and the “legal action against us” clause. The examination condition obligates

15 Goldman to sit for an examination under oath as often as Vigilant reasonably requires and to 16 provide additional requested documentation8: 17

1 The facts in this section are undisputed unless otherwise stated. 18 2 Vigilant is a member of the Chubb Group of Insurance Companies and is often referred to 19 elsewhere as “Chubb.” ECF 24 at ¶ 4 (Vigilant’s answer to the amended complaint). 3 ECF No. 33 at 5; ECF No. 33-2; ECF No. 79 at 3. The parties do not dispute that the policy 20 was in effect at the time of the loss. 21 4 ECF No. 65-21 at 2. 5 Id.; ECF No. 66-2 at 2. 22 6 ECF No. 33-2 at 32, 37 (the insurance policy). 23 7 Id. at 30. 8 Id. | Examination under oath. We have the right to examine separately under oath as often as we may reasonably require you, family members and any other members of your household and have them 2 subscribe the same. We may also ask you to give us a signed description of the circumstances surrounding a loss and your interest in it, and to produce all records and documents we request and 3 permit us to make copies,

4|| This provision is nested under the larger, ““Your duties after a loss” section, which lists 5|| Goldman’s obligations in the event of “a loss th[e] policy may cover.”’ The legal-action clause 6|| is contained in a separate “Special Conditions” section. It requires Goldman to comply with all conditions of the policy before bringing a lawsuit against Vigilant’: 8 Legal action against us You agree not to bring legal action against us unless you have first complied with all conditions of 9 this polky. For property, you ane agree to bring any action against us within one year after a loss occurs, but not unti ays after proof of loss has b i has been determined. P as been submitted to us and the amount of loss 10 11/10. The coverage dispute! 12 In 2016, Goldman submitted a property-damage claim against the policy related to a water leak under the slab of the guest house.!? The claim was complex, and Vigilant’s investigation into it involved geotechnical and structural engineering experts hired by both 15] Goldman and Vigilant to perform forensic evaluations and testing of the structure and soils. ! 16 Before that claim file was closed, on January 5, 2017, Goldman submitted an additional 17|| claim under the policy for damage to the main house.'* Later that same month, Vigilant responded with a reservation-of-rights letter stating, among other things, that no waiver or 19 Id. at 59. 20 10 Td. at 60. 21111] focus on the facts that relate to Goldman’s loss-of-use claim and refusal to comply with the examination-under-oath provision because they are dispositive. 22 ECF No. 23 at § 11 (amended complaint). Id. at § 12-25. '4 Td. at § 26; ECF No. 64-04.

1 estoppel was intended or should be inferred.15 Over the next three years, though Vigilant paid 2 out some benefits for this property-damage claim, the parties and their experts continued to 3 dispute the extent of the property damage and the necessary repairs.16 4 While negotiating that main-house, property-damage claim, Vigilant sent Goldman a

5 letter in May 2017, reminding him of the loss-of-use coverage his policy afforded “during the 6 period of restoration” due to its understanding that the property “house[d] sales staff, employees, 7 and people attending trade shows” and that “the home may not be available” for those guests 8 “once the repairs start[ed]” on the main and guest residences.17 In February of the next year, 9 Goldman submitted a loss-of-use claim for rental income he claimed he was no longer receiving 10 from Cels since the leak, and he also submitted a summary of damages and lease agreements 11 with Cels.18 12 That same month, Goldman inspected the property with Willie Mack, the first of 13 Vigilant’s claim representatives who was assigned to his case.19 Mack received the initial proof- 14 of-loss documentation and requested no further information,20 and his files included a note

15 reminding himself to “resolve issues related to the loss[-]of[-]use claim.”21 In April 2018, the 16 parties discussed the loss-of-use claim,22 and Vigilant’s internal files suggest that it was 17 18

15 ECF No. 64-29 at 4. 19 16 ECF No. 67-9 at 2. 20 17 ECF No. 65-18. 21 18 ECF Nos. 65-20, 65-21, 65-22, 65-23, 65-24. 19 ECF No. 33-15 at 2. 22 20 ECF No. 64-2 at 193:12–194:5. 23 21 ECF No. 65-26. 22 ECF No. 33-15 at 11–13. 1 investigating the claim in May.23 Those files reflect that the lease agreement with Cels was for 2 “business use[] and use for employees staying in the home for local trade shows” and that 3 Vigilant’s representative explained to Goldman that the home “was never uninhabitable.”24 4 Mack left his employment with Vigilant the next month.

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Goldman v. Vigilant Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/goldman-v-vigilant-insurance-company-nvd-2022.