Great American Alliance Insurance Company v. Auto-Owners Insurance Company

CourtDistrict Court, M.D. Florida
DecidedFebruary 11, 2025
Docket5:24-cv-00055
StatusUnknown

This text of Great American Alliance Insurance Company v. Auto-Owners Insurance Company (Great American Alliance Insurance Company v. Auto-Owners Insurance Company) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Great American Alliance Insurance Company v. Auto-Owners Insurance Company, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA OCALA DIVISION

GREAT AMERICAN ALLIANCE INSURANCE COMPANY, a foreign corporation,

Plaintiff,

v. Case No: 5:24-cv-55-WGY-PRL

AUTO-OWNERS INSURANCE COMPANY,

Defendant.

ORDER This matter is before the Court on Defendant Auto-Owners Insurance Company’s (“Auto-Owners”) motion to compel discovery responses from Plaintiff Great American Alliance Insurance Company (“Great American”). (Doc. 25). Great American has filed a response (Doc. 31), and thus this matter is ripe for review. I. Background This is an equitable subrogation action filed by Great American against Auto-Owners. Auto-Owners was the primary carrier, and Great American was the excess carrier for their common insureds, Summit Greens Resident’s Association, Inc. (“Summit Greens) and Leland Management, Inc. (“Leland”). This dispute arises from claims related to the same single occurrence—exposure to legionella in the hot tub on the Summit Greens’ property— and are subject to the per occurrence policy limits of the Auto-Owners Policy. The Plaintiffs in the Fischer Action1 sought damages for the wrongful death of Delmar Fischer and personal injuries to Karin Fischer. Likewise, the Plaintiffs in the Lewis Action2 sought damages for personal injuries to Charlie Lewis and loss of consortium to Dessie Larrita Brown-Lewis. Auto-Owners ultimately settled the Fischer Action and Great American settled the Lewis

Action. This matter is before the Court on Auto-Owners’ motion to compel complete discovery responses from Great American. (Doc. 25). At issue are Auto-Owners’ First Set of Interrogatories and First Request for Production that it propounded upon Great American on August 28, 2024. (Docs. 25-1, 25-3). Great American responded, raising various objections and providing what Auto-Owners contends are “non-responsive answers regarding matters that get to the heart of the current action.” (Docs. 25-2, 25-4). The instant motion tees up the parties differing views as to the obligations owed between the insurers under Florida law in a “multiple claimant single occurrence” scenario. In the complaint, Great American alleges that because it received late notice of the Lewis

Claim and Lewis Action by Auto-Owners, Auto-Owners is strictly liable to Great American for any sums it paid to settle the Lewis Action. In contrast, Auto-Owners argues that Great American must show that Auto-Owners had an opportunity to settle the Lewis Action and Fischer Action within the Auto-Owners Policy limits and failed to do so.3

1 Karin Fisher, ind. and as P.R. of the Est. of Delmar Fischer v. Summit Greens Residents’ Association, Inc., et al., Case No.: 35-2018-CA-001520. 2 Charlie Lewis and Dessie Larita Brown-Lewis v. Summit Greens Residents’ Association, Inc., Leland Management, Inc., and Roberts Pool Service and Repair, Inc., Case No. 2021-CA- 000858. 3 While Auto-Owners has not yet filed its answer, it has made its contrary position clear in other papers filed with the Court. For example, in its motion to dismiss, Auto-Owners argues inter alia that Great American cannot state a claim for relief because it has not and cannot allege that Auto-Owners had an opportunity to settle the Fischer Action within the limits of the Auto-Owners’ II. Legal Standards Motions to compel discovery under Rule 37(a) of the Federal Rules of Civil Procedure are committed to the sound discretion of the trial court. See Commercial Union Ins. Co. v. Westrope, 730 F.2d 729, 731 (11th Cir. 1984). “The overall purpose of discovery under the

Federal Rules is to require the disclosure of all relevant information so that the ultimate resolution of disputed issues in any civil action may be based on a full and accurate understanding of the true facts, and therefore embody a fair and just result.” Oliver v. City of Orlando, No. 6:06-cv-1671, 2007 WL 3232227, at *2 (M.D. Fla. Oct. 31, 2007). Indeed, parties are entitled to discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering various factors. Fed. R. Civ. P. 26(b)(1). Specifically: “Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the

amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Id. Under Rule 26, the Court has broad discretion to limit the time, place, and manner of discovery as required “to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense.” Fed. R. Civ. P. 26(c). The Court’s exercise of discretion to appropriately fashion the scope and effect of discovery will be sustained unless it abuses that discretion to the prejudice of a party. Amey, Inc. v. Gulf Abstract & Title, Inc., 758

Policy limits, thereby exposing Great American to amounts it would not otherwise have had to pay.” (Doc. 10 at 7). F.2d 1486, 1505 (11th Cir.1985); see also Moore v. Armour Pharm. Co., 927 F.2d 1194, 1197 (11th Cir.1991) (“The trial court ... has wide discretion in setting the limits of discovery, and its decisions will not be reversed unless a clearly erroneous principle of law is applied, or no evidence rationally supports the decision.”).

Relevancy and proportionality are the guiding principles. The moving party “bears the initial burden of proving that the information sought is relevant.” Douglas v. Kohl’s Dep’t Stores, Inc., No. 6:15-cv-1185, 2016 WL 1637277, at *2 (M.D. Fla. Apr. 25, 2016) (quoting Moore v. Lender Processing Servs. Inc., No. 3:12-cv-205, 2013 WL 2447948, at *2 (M.D. Fla. June 5, 2013)). Relevancy is based on the “tendency to make a fact more or less probable than it would be without the evidence, and the fact is of consequence in determining the action.” Garcia v. Padilla, No. 2:15-cv-735, 2016 WL 881143, at *2 (M.D. Fla. March 8, 2016) (quoting Fed. R. Evid. 401). The Courts and the parties must consider and evaluate “the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to

relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b) (1) (“The parties and the court have a collective responsibility to consider the proportionality of all discovery and consider it in resolving discovery disputes.” Comment, 2015 Amendment). III. Discussion Auto-Owners has moved to compel better responses to Interrogatories #4 through #13 and #16 and to Requests for Production #1 through #13, #15 through #20, and #22 through #29. Interrogatory #4 seeks the damages being claimed by Great American and the basis for them. As an initial matter, it appears that the issue of the settlement agreement has been largely resolved (see e.g., Doc.

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Great American Alliance Insurance Company v. Auto-Owners Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/great-american-alliance-insurance-company-v-auto-owners-insurance-company-flmd-2025.