Greene v. State Farm Fire and Casualty Company

CourtDistrict Court, N.D. Oklahoma
DecidedSeptember 19, 2023
Docket4:22-cv-00135
StatusUnknown

This text of Greene v. State Farm Fire and Casualty Company (Greene v. State Farm Fire and Casualty Company) is published on Counsel Stack Legal Research, covering District Court, N.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Greene v. State Farm Fire and Casualty Company, (N.D. Okla. 2023).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OKLAHOMA

PAUL D. GREENE and ) MICHELLE GREENE, ) ) Plaintiffs, ) ) v. ) Case No. 22-cv-135-CDL ) STATE FARM FIRE AND ) CASUALTY COMPANY, ) ) Defendant. )

OPINION AND ORDER

I. Background This case arises from the plaintiffs’ claims under a homeowners’ insurance policy issued by the defendant. On July 11, 2023, District Judge Gregory K. Frizzell denied the defendant’s motion for summary judgment as to (1) the plaintiffs’ breach of contract claim and (2) the plaintiffs’ bad faith claim as it relates to an inadequate investigation of the plaintiffs’ claim for water damage to the interior of their home. (Doc. 60). Judge Frizzell granted summary judgment as to the bad faith claim in all other respects. See id. Subsequently, the parties consented to the undersigned conducting all further proceedings in this case, and Judge Frizzell signed the order of referral to the undersigned. See 28 U.S.C. § 636(c) and Fed. R. Civ. P. 73. Before the Court are several motions in limine filed by the defendant (Doc. 36, 37, 38, 39) and the plaintiffs’ motion to exclude the testimony and written report of defendant’s expert, Michael J. Berryman. (Doc. 40). The Court has considered all briefing filed by the parties on the motions and heard oral arguments on certain of the issues set forth herein. II. Defendant’s Motions to Exclude

A. Standards Applicable to Motions in Limine District courts have discretion to make preliminary rulings to exclude certain evidence. A motion in limine is a “‘pretrial request that certain inadmissible evidence not be referred to or offered at trial.’” Edens v. The Netherlands Ins. Co., 834 F.3d 1116, 1130 (10th Cir. 2016) (quoting Black's Law Dictionary (10th ed. 2014)). “The purpose of a

motion in limine is to aid the trial process by enabling the Court to rule in advance of trial on the relevance of certain forecasted evidence, as to issues that are definitely set for trial, without lengthy argument at, or interruption of, the trial.” Mendelsohn v. Sprint/United Mgmt. Co., 587 F. Supp. 2d 1201, 1208 (D. Kan. 2008) aff’d, 402 F. App’x 337 (10th Cir. 2010) (internal quotations omitted).1 In-limine rulings are preliminary and are subject to

change at the court’s discretion. Luce v. United States, 469 U.S. 38, 41-42 (1984). While pretrial in-limine rulings can save time and avoid interruptions at trial, “a court is almost always better situated during actual trial to assess the value and utility of evidence.” Koch v. Koch Ind., Inc., 2 F. Supp. 2d 1385, 1388 (D. Kan. 1998). “For this

1 The admissibility of evidence is generally governed by federal law in a case based on diversity jurisdiction, as this case is. Blanke v. Alexander, 152 F.3d 1224, 1231 (10th Cir. 1998). In determining the admissibility of evidence, courts consider state law only to the extent an issue involves “a ‘substantive’ state rule of evidence, such as the collateral source rule or the parol evidence rule.” Fees v. Am. Fam. Life Ins. Co., No. 19-cv-476- CVE-JFJ, 2021 WL 2104990, at *1 (N.D. Okla. May 25, 2021) (unpublished) (citing Blanke). reason, some courts defer making in limine rulings unless the ‘evidence is clearly inadmissible on all potential grounds.’” Id. (quoting Hawthorne Partners v. AT&T Techs., Inc., 831 F. Supp. 1398, 1400 (N.D. Ill. 1993) (“Unless evidence meets this high standard,

evidentiary rulings should be deferred until trial so that questions of foundation, relevancy and potential prejudice may be resolved in proper context.”)). Additionally, the movant has the burden to demonstrate that the evidence is inadmissible on any permissible ground, and motions in limine that lack specificity are properly denied. See Rooney v. State Farm Fire & Cas. Co., 2023 WL 3078332, *1 (D. Colo. Apr. 25, 2023); see also First Savings Bank

v. U.S. Bancorp, 117 F. Supp. 2d 1078, 1082 (D. Kan. 2000). B. Punitive Damages (Doc. 38) The defendant moves for an order excluding evidence relating to punitive damages, including evidence or argument within the following categories: A. Any and all evidence or argument about punitive damages; B. Evidence or argument until after the jury has awarded compensatory damages; C. Evidence or argument concerning Categories II and III of Oklahoma’s punitive damages statute; D. Evidence or argument of State Farm’s net worth, cash reserves, revenues, income, profit margin, or assets; E. Evidence or argument related to State Farm’s activities outside the state of Oklahoma; F. Evidence or argument concerning conduct affecting or directed at persons other than Plaintiffs; G. “Send a message” arguments; and H. References to punitive damages in opening statement.

(Doc. 38 at 1). The plaintiffs concede category H above, but otherwise oppose the motion in general fashion and argue that the motion to exclude is premature. (See Doc. 47). Under Oklahoma law, if a jury finds by clear and convincing evidence that an “insurer has recklessly disregarded its duty to deal fairly and act in good faith with its insured,” a plaintiff who prevails on a bad faith claim may recover “punitive damages in

an amount not to exceed the greater of” $100,000 or the amount of the actual damages awarded. Okla. Stat. tit. 23, § 9.1(B). Those are “Category I” damages under the statute. See id. Category II damages provide for a higher punitive damages cap of the greater of $500,000, twice the amount of actual damages awarded, or the increased financial benefit to the insurer as a direct result of the conduct causing plaintiffs’ injury and other persons

or entities, upon a finding by the jury that the insurer acted intentionally and with malice. See id., § 9.1(C). Here, because the plaintiffs’ tort claim for bad faith based on an inadequate investigation remains to be tried and determined by a jury, and the Court did not grant summary judgment as to punitive damages, it is not appropriate to enter a pretrial order

excluding all evidence concerning punitive damages. However, such evidence may be introduced only if and after the jury has made a sufficient finding as to liability and has found the recklessness or malice required to warrant consideration of punitive damages. The trial will be conducted in two phases, consistent with the practice in this Court in insurance cases with bad faith claims and consistent with the plain language of the

Oklahoma punitive damages statute. See, e.g., Terril v. State Farm Mut. Auto. Ins. Co., 07- CV-228-CVE-PJC, 2007 WL 2344701, *1 (N.D. Okla. 2007); Watson v. Farmers Ins. Co., Inc., 12-CV-391-JED-PJC, 2014 WL 2457243, *3 (N.D. Okla. Jun. 2, 2014); Okla. Stat. tit. 23, § 9.1(B), (C) (“the jury, in a separate proceeding conducted after the jury has made” a finding of reckless disregard or malice, may award punitive damages).

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Related

Luce v. United States
469 U.S. 38 (Supreme Court, 1984)
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Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
Blanke v. Alexander
152 F.3d 1224 (Tenth Circuit, 1998)
Koch v. Koch Industries, Inc.
203 F.3d 1202 (Tenth Circuit, 2000)
Mendelsohn v. Sprint/United Management Co.
402 F. App'x 337 (Tenth Circuit, 2010)
United States v. Harold Featherston
325 F.2d 539 (Tenth Circuit, 1963)
United States v. Grant C. Affleck
776 F.2d 1451 (Tenth Circuit, 1985)
Wilson v. Merrell Dow Pharmaceuticals Inc.
893 F.2d 1149 (Tenth Circuit, 1990)
Mendelsohn v. Sprint/United Management Co.
587 F. Supp. 2d 1201 (D. Kansas, 2008)
Hawthorne Partners v. AT & T TECHNOLOGIES, INC.
831 F. Supp. 1398 (N.D. Illinois, 1993)
First Savings Bank, FSB v. US Bancorp
117 F. Supp. 2d 1078 (D. Kansas, 2000)
Koch v. Koch Industries, Inc.
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Edens v. Netherlands Insurance
834 F.3d 1116 (Tenth Circuit, 2016)

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Greene v. State Farm Fire and Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greene-v-state-farm-fire-and-casualty-company-oknd-2023.