GRIFFIN v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY

CourtDistrict Court, E.D. Pennsylvania
DecidedApril 25, 2025
Docket2:25-cv-01682
StatusUnknown

This text of GRIFFIN v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY (GRIFFIN v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GRIFFIN v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

AVIS GRIFFIN : CIVIL ACTION : v. : NO. 25-1682 : STATE FARM MUTUAL : AUTOMOBILE INSURANCE : COMPANY :

MEMORANDUM

KEARNEY, J. April 25, 2025 Avis Griffin purchased car insurance from State Farm. State Farm agreed to pay for Ms. Griffin’s covered losses arising from an accident with an uninsured driver. Ms. Griffin contractually agreed she would sue both State Farm and the uninsured driver for recovery if she challenged State Farm’s uninsured motorist coverage decision. Ms. Griffin and Bessy Hernandez-Valladares got into a car accident in May 2022. The local police found Ms. Griffin liable for the accident. She disagrees. Ms. Griffin learned State Farm accepted liability for the accident and, based on its determination, denied her uninsured motorist coverage. State Farm suggested Ms. Griffin make a claim under Ms. Hernandez-Valladares’s insurance policy. She did, but Ms. Hernandez-Valladares’s insurer denied coverage. So, Ms. Griffin returned to State Farm to seek uninsured benefits. She pro se sued her insurer State Farm last year but did not sue Ms. Hernandez-Valladares. We dismissed with leave to amend to add Ms. Hernandez-Valladares as required by the State Farm policy but Ms. Griffin decided to dismiss without prejudice while she found an attorney. No luck in finding a lawyer, but she now returns pro se suing State Farm again for breach of the insurance policy and bad faith without adding Ms. Hernandez-Valladares to the case. State Farm moves to dismiss. We agree with State Farm again. We again grant Ms. Griffin leave to timely amend to name Ms. Hernandez-Valladares to her contract claim (if otherwise timely) and to possibly plead facts of State Farm’s bad faith. I. Alleged Facts Avis Griffin purchased car insurance from State Farm Mutual Automobile Insurance Company. She agreed to State Farm’s conditions which would allow her to sue State Farm for

losses she may incur from an accident with an uninsured or underinsured driver.1 Ms. Griffin agreed to language in State Farm’s Policy addressing when she can sue State Farm for uninsured benefits. These conditions in State Farm’s Policy, known as “Deciding Fault and Amount,” define when the insured, like Ms. Griffin, can sue State Farm for uninsured motor vehicle coverage: “1.a. The insured and we must agree to the answers to the following two questions; (1) Is the insured legally entitled to recover compensatory damages from the owner or driver of the uninsured motor vehicle? (2) If the insured and we agree that the answer to 1.a.(1) above is yes, then what is the amount of the compensatory damages that the insured is legally entitled to recover from the owner or driver of the uninsured motor vehicle? If there is no

agreement on the answer to either question in 1.a. above, then the insured shall: (1) file a lawsuit, in a state or federal court that has jurisdiction, against: (a) us; (b) the owner and driver of the uninsured motor vehicle unless we have consented to a settlement offer proposed by or on behalf of such owner or driver; and (c) any other party or parties who may be legally liable for the insured’s damages[.]”2 Ms. Griffin and another driver Bessy Hernandez-Valladares got into a car accident in Norristown on May 19, 2022.3 Norristown Borough police responded to the accident and prepared a police report attributing liability for the accident to Ms. Griffin, not Ms. Hernandez-Valladares.4 Ms. Griffin disagreed with the police report, believes fault should have been attributed to Ms. Hernandez-Valladares, and reported her disagreement with the police report to State Farm.5 Ms. Griffin now pleads State Farm accepted full liability shortly after the accident based on the police report and other evidence without telling her. 6 Ms. Griffin demanded uninsured motorist benefits under her Policy with State Farm, seeking $385,000 to compensate her for

“physical pain and emotional distress, future pain and suffering, future medical and wage loss salary.”7 State Farm responded by denying Ms. Griffin’s demand for uninsured motorist benefits because it determined Ms. Griffin is liable for the accident making the Policy’s uninsured motorist benefits inapplicable.8 II. Analysis Ms. Griffin pro se sued her insurer State Farm Mutual Automobile Insurance Company for “uninsured motorist benefits,” breach of contract, and bad faith under Pennsylvania statute, 42 Pa. Cons. Stat. Ann. § 8371, in the Montgomery County Court of Common Pleas on March 17, 2025.9 State Farm removed to this Court and now moves to dismiss Ms. Griffin’s amended Complaint with prejudice.10 Ms. Griffin opposes State Farm’s motion.11 We again dismiss the amended

Complaint without prejudice. A. Ms. Griffin does not plead breach of contract. Ms. Griffin asserts two contract claims: one for uninsured benefits and the other for breach of contract, essentially asserting the same claim by alleging the Policy allows for uninsured motorist benefits, State Farm breached the Policy by refusing to pay uninsured motorist benefits, and resulting damages. State Farm asks us to dismiss Ms. Griffin’s contract claims. State Farm argues: (1) Ms. Griffin did not allege Ms. Hernandez-Valladares was uninsured at the time of the accident or, if insured, the limits of insurance were less than required or Ms. Hernandez-Valladares’s insurer denied its policy provided liability coverage resulting from the accident; (2) a condition precedent of uninsured motorist coverage under the Policy requires Ms. Griffin and State Farm to agree Ms. Griffin is legally entitled to recover from Ms. Hernandez-Valladares and, because State Farm accepted full liability for the accident, Ms. Griffin cannot allege she and State Farm agreed; and

(3) the applicable Policy provision triggered when Ms. Griffin and State Farm disagreed on her entitlement to recovery requires Ms. Griffin to sue State Farm and Ms. Hernandez-Valladares and any other necessary party Ms. Griffin believes may be legally liable for her damages and she did not do so.12 We address each argument in turn. We are not persuaded by State Farm’s first argument Ms. Griffin did not allege Ms. Hernandez-Valladares is uninsured.13 Ms. Griffin specifically alleged “[t]he other driver was uninsured.”14 Ms. Griffin also attached to her Complaint a letter from Ms. Hernandez-Valladares’s insurer, American Freedom Insurance Company, denying Ms. Griffin’s claim under the American Freedom policy.15 Accepting as true this allegation and construing it in Ms. Griffin’s favor, we

may reasonably infer Ms. Hernandez-Valladares was not insured at the time of the accident. State Farm’s second and third contract arguments are two sides of the same coin. Under its Policy’s Deciding Default and Amount provision, Ms. Griffin and State Farm “must agree to the answers to ... two questions:” (1) Is Ms. Griffin legally entitled to recover compensatory damages from the owner or driver of the uninsured motor vehicle, Ms. Hernandez-Valladares? and (2) If Ms. Griffin and State Farm agree the answer to the first question is yes, then what is the amount of compensatory damages to which Ms. Griffin is legally entitled to recover from the uninsured Ms. Hernandez-Valladares?16 When Ms. Griffin and State Farm disagreed on the answer to these two questions, State Farm’s Policy’s Deciding Fault and Amount provision required Ms. Griffin to file a lawsuit against State Farm, the owner and driver of the uninsured vehicle, and any other party who may be legally liable for Ms. Griffin’s damages. Ms. Griffin did not do so; she sued only State Farm. Ms. Griffin did not meet the terms of the Policy. Ms.

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Bluebook (online)
GRIFFIN v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/griffin-v-state-farm-mutual-automobile-insurance-company-paed-2025.