Guerrera v. United Financial Casualty Company

CourtDistrict Court, E.D. Louisiana
DecidedFebruary 18, 2025
Docket2:24-cv-01354
StatusUnknown

This text of Guerrera v. United Financial Casualty Company (Guerrera v. United Financial Casualty Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guerrera v. United Financial Casualty Company, (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

SANTO GUERRERA CIVIL ACTION

VERSUS NO: 2:24-cv-1354

UNITED FINANCIAL CASUALTY SECTION: T (1) COMPANY, et al. ORDER AND REASONS Before the Court are various Motions to Dismiss and Motions for Summary Judgment regarding two legal issues. For the following reasons, defendants Rasier, LLC (“Rasier”) and Uber Technologies, Inc.’s (“Uber”), Motion to Dismiss, R. Doc. 13, and defendant United Financial Casualty Company’s (“UFCC”) Motion for Summary Judgment, R. Doc. 15, are GRANTED. Plaintiff’s, Santo Guerrera, Motion for Summary Judgment, R. Doc. 12, is DENIED. Plaintiff’s Motion to Certify to the Louisiana Supreme Court, R. Doc. 53, is DENIED AS MOOT. Secondly, Defendant Certain Underwriters of Lloyd’s, London (“Lloyd’s”) Cross-Motion for Summary Judgment, R. Doc. 62, is GRANTED. Plaintiff’s Motion for Partial Summary Judgment against Lloyd’s, R. Doc. 44, is accordingly DENIED. BACKGROUND This lawsuit arises from a car accident on February 11, 2023 (“the Accident”). Defendant Rasier is a wholly-owned subsidiary of Uber, a “transportation network company” (“TNC”) that facilitates rideshare services between drivers and passengers via a popular mobile-phone 1 application (“the Uber App”).1 See R. Doc. 1-1. UFCC is the alleged uninsured/underinsured motorist (“UM”) carrier for Rasier. R. Doc. 13-1 at p. 2. Plaintiff was a passenger in a “pre- arranged ride” with driver, Louis Faciane, (“the Uber driver”) via the Uber App. Id.2 The accident occurred on a Saturday during Mardi Gras season. R. Doc. 60-3 at p. 3.

Plaintiff first left his house in his own vehicle around midday and drove to his friend William McKay’s residence. Id. Plaintiff is the sole owner, operator, and member of Smart Well Solutions, LLC (“SWS”), a limited liability company for Plaintiff’s deepwater well construction consulting services. R. Doc. 69-1 at p. 1. McKay however does not have a business relationship with SWS. R. Doc. 60-3 at p. 5. Plaintiff left his car at McKay’s house and called for a ride via the Uber App from McKay’s residence to a local restaurant for lunch. Id. at p. 3. The two ate lunch at the restaurant, and then watched a Mardi Gras parade. Id. at pp. 3-4. After the parade, Plaintiff called another ride on the Uber App to transport him and McKay back to McKay’s residence. Id. On the way back to McKay’s house, the Accident allegedly occurred at the Claiborne and Jackson Avenue intersection in New Orleans. R. Doc. 12 at p. 2; R. Doc. 60-3 at p. 8. Plaintiff alleges another

1 La. R.S. 42.201.4(6) defines “‘[t]ransportation network company’ [as] a person, whether natural or juridical, that uses a digital network to connect transportation network company riders to transportation network company drivers who provide prearranged rides, or a person, whether natural or juridical, that provides a technology platform to a transportation network company rider that enables the transportation network company rider to schedule a prearranged ride.”

2 La. R.S. 45:201.4(4) defines “prearranged ride” as the provision of transportation by a driver to a rider that commences when a driver accepts a ride requested by a person through a digital network controlled by a transportation network company, continues during the driver transporting a requesting rider, and ends when the last requesting rider departs from the personal vehicle.” 2 vehicle struck the Uber driver’s vehicle in a hit-and-run accident leaving him with personal injuries. Id. At the time of the Accident, UFCC issued an automobile insurance policy issued to Rasier, LLC providing liability limits of $1,000,000.00 CSL and but no UM coverage (“the UFCC

policy”). R. Doc. 12-1 at p. 3. Rasier executed an Uninsured/Underinsured Motorist Bodily Injury Coverage Form signed by Amy E. Wagner, employed at the time as Head of North American Insurance for Uber (“the UFCC rejection form”). See R. Doc. 15-4. Wagner’s initials appear next to the box which states “I do not want UMBI Coverage. I understand that I will not be compensated [for] UMBI coverage for losses arising from an accident caused by an uninsured/underinsured motorist.” R. Doc. 15-4 at p. 11. Plaintiff does not dispute that the UFCC rejection form exists and purportedly rejects UM coverage. R. Doc. 12-1 at p. 2. Also at issue is a commercial general liability insurance policy, No. HISOG61P, issued to SWS from Defendant Lloyd’s (“the Lloyd’s policy”). R. Doc. 44-4. The policy lists SWS, not Plaintiff, as the “Named Insured.” R. Doc. 44-4 at p. 1. The LLC’s members are later included as

“‘insureds’, but only with respect to the conduct of [the] business.” Id. at p. 18. There is no language in the Lloyd’s policy expressly providing for UM coverage. See generally id. Further, the Lloyd’s policy contained an auto liability exclusion exempting coverage to “autos,” except for when “bodily injury…relates solely and exclusively to the conduct of the ‘insured’s’ business and if only carried out by an ‘insured.’” Id. at p. 13. Lloyd’s also provided a form attached to the Lloyd’s policy which states in part: “APPLICABLE ONLY IN LOUISIANA: 3 I ACKNOWLEDGE THAT UM COVERAGE HAS BEEN EXPLAINED TO ME, AND I HAVE BEEN OFFERED THE OPTION OF SELECTING UM LIMITS EQUAL TO MY LIABILITY LIMITS, UM LIMITS LOWER THAN MY LIABILITY LIMITS, OR TO REJECT UM COVERAGE ENTIRELY….2. I REJECT UM COVERAGE IN ITS ENTIRETY. [SG]”

(“the Lloyd’s waiver”). R. Doc. 44-6. This waiver has Plaintiff’s initials next to the box rejecting UM coverage and is signed and dated October 11, 2022. Id. However, the Lloyd’s waiver does not use the current UM rejection form, Bulletin 08-02, that the Louisiana Commissioner of Insurance allegedly requires. See R. Doc. 44-1 at pp. 9-10. LAW AND ANALYSIS 1. Legal Standard Federal Rule of Civil Procedure 12(b)(6) allows a defendant to seek dismissal of a complaint based on the “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleases factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. Under Fed. R. Civ. P. 8(a), a “short and plain statement of the claim” is required. Id. When evaluating a 12(b)(6) motion, the Court must “take the well-pled factual allegations of the complaint as true and view them in the light most favorable to the plaintiff.” Lane v. Halliburton, 529 F.3d 548, 557 (5th Cir. 2008) (citing In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007)). However, 4 a court “do[es] not accept as true conclusory allegations, unwarranted factual inferences, or legal conclusions.” Plotkin v. IP Axess Inc., 407 F.3d 690, 696 (5th Cir. 2005). Summary judgment on the other hand is proper when “the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Little v. Liquid Air Corp.
37 F.3d 1069 (Fifth Circuit, 1994)
Plotkin v. IP Axess Inc.
407 F.3d 690 (Fifth Circuit, 2005)
Lane v. Halliburton
529 F.3d 548 (Fifth Circuit, 2008)
Martco Ltd. Partnership v. Wellons, Inc.
588 F.3d 864 (Fifth Circuit, 2009)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
In Re Katrina Canal Breaches Litigation
495 F.3d 191 (Fifth Circuit, 2007)
Magnon v. Collins
739 So. 2d 191 (Supreme Court of Louisiana, 1999)
CAMPAIGN FOR a LIVING WAGE v. New Orleans
825 So. 2d 1098 (Supreme Court of Louisiana, 2002)
Robinson v. Heard
809 So. 2d 943 (Supreme Court of Louisiana, 2002)
Daigle v. Authement
691 So. 2d 1213 (Supreme Court of Louisiana, 1997)
Dean v. State Farm Mut. Auto. Ins. Co.
975 So. 2d 126 (Louisiana Court of Appeal, 2008)
Taylor v. Rowell
736 So. 2d 812 (Supreme Court of Louisiana, 1999)
Duncan v. USAA Ins. Co.
950 So. 2d 544 (Supreme Court of Louisiana, 2007)
Filipski v. Imperial Fire & Casualty Insurance Co.
25 So. 3d 742 (Supreme Court of Louisiana, 2009)
Pierce Foundations, Inc. v. Jaroy Construction, Inc.
190 So. 3d 298 (Supreme Court of Louisiana, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Guerrera v. United Financial Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guerrera-v-united-financial-casualty-company-laed-2025.