Greenfield v. American Security Insurance Company

CourtDistrict Court, N.D. California
DecidedJune 2, 2025
Docket3:25-cv-03416
StatusUnknown

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

Bluebook
Greenfield v. American Security Insurance Company, (N.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 PAUL GREENFIELD, Case No. 25-cv-03416-LB

12 Plaintiff, ORDER GRANTING MOTION TO 13 v. DISMISS

14 AMERICAN SECURITY INSURANCE Re: ECF No. 6 COMPANY, 15 Defendant. 16 17 INTRODUCTION 18 The plaintiff has a secured interest in a residential property that was damaged in a fire. Wells 19 Fargo assigned that interest to him. The defendant insurer paid Wells Fargo for the cost of the 20 damage, but there was a dispute as to whether Wells Fargo paid the correct amount. After 21 receiving the assignment, the plaintiff filed an action claiming a bad-faith denial of insurance 22 benefits. The defendant moved to dismiss for failure to state a claim. 23 The court grants the motion to dismiss with leave to amend because the claim is time-barred 24 by the insurance policy, and the complaint does not plausibly allege equitable tolling. 25 26 27 1 STATEMENT 2 1. Factual Background 3 The plaintiff Paul Greenfield filed this action as an assignee of Wells Fargo’s secured interest 4 in a vacant residential property located at 224 Sea Cliff Avenue in San Francisco, California.1 In 5 July 2021, the defendant American Security Insurance Company issued a Residential Dwelling 6 Insurance Certificate for Wells Fargo covering the property from July 18, 2021, to July 18, 2022.2 7 The Certificate identified Brugnara Properties as the borrower on the loan.3 The Certificate states: 8 “Actions Against Us. No action can be brought unless the Certificate provisions have been 9 complied with and the action is started within two years after the date of loss.”4 Under the 10 Certificate, American Security “shall pay no more than the named insured’s interest in the 11 property at the time of the loss.”5 Wells Fargo’s interest is represented by the loan balance, which 12 is limited to only the unpaid loan balance plus earned interest as of the date of loss.6 13 On July 15, 2022, a partial fire caused damage to the property, and the damage was reported to 14 the defendant on July 20, 2022.7 Wells Fargo filed an insurance claim for the damage on July 20, 15 2022.8 On January 6, 2023, the defendant paid Wells Fargo $402,190.53 in accordance with a 16 repair estimate prepared by an independent insurance adjuster.9 Wells Fargo requested additional 17 payment, and American Security refused.10 18 In May 2023, PSG Mortgage Lending Corp., a subsequent owner of the property, filed a 19 petition for Chapter 11 bankruptcy protection in the U.S. Bankruptcy Court for the Northern 20 21 1 Compl. – ECF No. 1-1 at 17–18 (¶¶ 1, 6). Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents. 22 2 Id. at 18 (¶ 6); Decls. & Certificate, Ex. A to Laurence Decl. – ECF No. 6-2 at 12–13. 23 3 Decls., Ex. A to Laurence Decl. – ECF No. 6-2 at 12. 4 Certificate, Ex. A to Laurence Decl. – ECF No. 6-2 at 24. 24 5 Id. at 18. 25 6 Id. at 14, 18. 26 7 Compl. – ECF No. 1-1 at 18 (¶ 7); Loss Notice, Ex. C to Laurence Decl. – ECF No. 12-1 at 4. 8 Loss Notice & Letter, Exs. C–D to Laurence Decl. – ECF No. 12-1 at 4, 6. 27 9 Letter, Ex. D to id. – ECF No. 12-1 at 6–7; Assignment, Ex. A to Laurence Decl. – ECF No. 6-2 at 9. 1 District of California. The Bankruptcy Court granted the motion of PSG to sell the property free 2 and clear of all liens and interests.11 The property was sold on February 5, 2024, and as a senior 3 lienholder, Wells Fargo received $5,915,815.03 from the sale proceeds. The other lienholders, 4 including the plaintiff, did not receive any payments from the sale of the property.12 5 Wells Fargo assigned rights under the Certificate to the plaintiff in December 2024. In the 6 assignment, Wells Fargo disclaimed any representations or warranties regarding the nature, extent, or 7 value of those rights, including the recoverability of additional sums from American Security.13 The 8 plaintiff filed their complaint claiming bad-faith denial of insurance coverage on January 6, 2025.14 9 10 2. Procedural History 11 The plaintiff filed the complaint in state court, and the defendant removed it to this court.15 12 The court has diversity jurisdiction under 28 U.S.C. § 1332.16 All parties consented to magistrate- 13 judge jurisdiction under 28 U.S.C. § 636(c).17 The court can decide the motion without oral 14 argument. Civil L.R. 7-1(b). 15 LEGAL STANDARD 16 A complaint must contain a “short and plain statement of the claim showing that the pleader is 17 entitled to relief” to give the defendant “fair notice” of (1) what the claims are and (2) the grounds 18 upon which they rest. Fed. R. Civ. P. 8(a)(2); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 19 (2007). Thus, “[a] complaint may fail to show a right to relief either by lacking a cognizable legal 20 theory or by lacking sufficient facts alleged under a cognizable legal theory.” Woods v. U.S. Bank 21 N.A., 831 F.3d 1159, 1162 (9th Cir. 2016). 22 23 11 Debtor’s Stip., Ex. A to Laurence Decl. – ECF No. 6-2 at 3. 24 12 Id. at 3–4. 25 13 Assignment, Ex. A to Laurence Decl. – ECF No. 6-2 at 9–10. 26 14 Compl. – ECF No. 1-1 at 17–20. 15 Notice of Removal – ECF No. 1. 27 16 Id. 1 A complaint does not need detailed factual allegations, but “a plaintiff’s obligation to provide 2 the ‘grounds’ of his ‘entitlement to relief’ requires more than labels and conclusions, and a 3 formulaic recitation of the elements of a cause of action will not do. Factual allegations must be 4 enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555 (cleaned 5 up). A complaint must contain factual allegations that, when accepted as true, are sufficient to 6 “state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); 7 NorthBay Healthcare Grp., Inc. v. Kaiser Found. Health Plan, Inc., 838 F. App’x 231, 234 (9th 8 Cir. 2020) (“[O]nly the claim needs to be plausible, and not the facts themselves . . . .”); see 9 Interpipe Contracting, Inc. v. Becerra, 898 F.3d 879, 886–87 (9th Cir. 2018) (the court must 10 accept the factual allegations in the complaint “as true and construe them in the light most 11 favorable to the plaintiff” (cleaned up)). 12 Put another way, “[a] claim has facial plausibility when the plaintiff pleads factual content that 13 allows the court to draw the reasonable inference that the defendant is liable for the misconduct 14 alleged.” Iqbal, 556 U.S. at 678. “The plausibility standard is not akin to a ‘probability 15 requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.” 16 Id. “Where a complaint pleads facts that are merely consistent with a defendant’s liability, it stops 17 short of the line between possibility and plausibility of ‘entitlement to relief.’” Id. (cleaned up). 18 If a court dismisses a complaint because of insufficient factual allegations, it should give leave 19 to amend unless “the pleading could not possibly be cured by the allegation of other facts.” Cook, 20 Perkiss & Liehe, Inc. v. N. Cal. Collection Serv. Inc., 911 F.2d 242, 247 (9th Cir. 1990). If a court 21 dismisses a complaint because its legal theory is not cognizable, the court should not give leave to 22 amend. United States v. United Healthcare Ins.

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Bluebook (online)
Greenfield v. American Security Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greenfield-v-american-security-insurance-company-cand-2025.