Hale v. Country Mutual Insurance Company

CourtDistrict Court, W.D. Washington
DecidedJune 23, 2020
Docket3:19-cv-06059
StatusUnknown

This text of Hale v. Country Mutual Insurance Company (Hale v. Country Mutual Insurance Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hale v. Country Mutual Insurance Company, (W.D. Wash. 2020).

Opinion

1 HONORABLE RONALD B. LEIGHTON 2 3 4 5

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT TACOMA 8 PAMELA HALE, CASE NO. 3:19-CV-06059-RBL 9 Plaintiff, ORDER ON PLAINTIFF’S MOTION 10 v. FOR LEAVE TO AMEND COMPLAINT 11 COUNTRY MUTUAL INSURANCE COMPANY, 12 Defendant. 13

14 INTRODUCTION 15 THIS MATTER is before the Court on Plaintiff Pamela Hale’s Motion for Leave to 16 Amend Complaint. Dkt. # 15. Hale sued Defendant Country Mutual Insurance Company on 17 October 3, 2019 in Clark County Superior Court for breach of contract, failure to act in good 18 faith, and negligent misrepresentation. Dkt. # 1-2. The Complaint contains little-to-no factual 19 allegations. Id. Country Mutual removed to federal court on November 7, 2019, and Hale did not 20 move to remand. Hale would now like to amend her Complaint to add new factual allegations, 21 new claims, and, most controversially, a new defendant. Country Wide opposes the Motion on 22 the basis that the new defendant—insurance agent Ann Campbell-VanDyke —is non-diverse and 23 would destroy federal subject matter jurisdiction. 24 1 BACKGROUND 2 Hale’s Proposed First Amended Complaint alleges that Hale’s Property was burglarized 3 in August 2018. Proposed FAC, Dkt. # 17-6, at 2-3. At the time, Hale had been off the premises 4 because of stalking and threats by the romantic partner of Hale’s daughter. Id. Hale discovered 5 the burglary in September 2018 and notified police. Id. at 3.

6 She also tendered claims to Country Mutual, which insured the Property, through 7 insurance agent Ann Campbell-VanDyke. Id. at 3. Campbell-VanDyke is a resident of 8 Washington State. Id. at 2. Hale had been in contact with Campbell-VanDyke for years to make 9 changes to the insurance for Hale’s Property. Id. Despite the fact that Campbell-VanDyke knew 10 Hale was living away from the Vancouver Property, Campbell-VanDyke recommended keeping 11 it as Hale’s principal residence and dwelling in the policy. Id. at 3-4. Campbell-VanDyke also 12 apparently informed Hale that she had two years to complete her claim. Id. at 4. It was not until 13 May 2019 that Campbell-VanDyke began processing Hale’s claim. Id. At that time, Campbell- 14 VanDyke also informed Hale that she actually only had one year to complete her claim but that

15 her policy did not have a 60-day occupancy exclusion. Id. at 5. 16 Shortly thereafter, a Country Mutual representative contacted Hale and told her that she 17 had until August 2019 to submit a complete list of the items lost from the house with original 18 receipts. Id. Many of these items Hale had already paid to replace. Id. Still without a final 19 decision, Hale filed suit to avoid the one-year limitation period. Id. at 6. Country Mutual asked 20 for additional documentation from Hale and asked her to sit for an oral examination. Id. 21 Nonetheless, Country Mutual formally denied Hale’s claim on April 3, 2020, citing the policy’s 22 unoccupied dwelling exclusion, the Property’s primary residence status, and the extent of 23 coverage in the policy. Id. at 6-7. 24 1 DISCUSSION 2 Leave to amend a complaint under Fed. R. Civ. P. 15(a) “shall be freely given when 3 justice so requires.” Carvalho v. Equifax Info. Services, LLC, 629 F.3d 876, 892 (9th Cir. 2010) 4 (citing Forman v. Davis, 371 U.S. 178, 182 (1962)). This policy is “to be applied with extreme 5 liberality.” Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048, 1051 (9th Cir. 2003)

6 (citations omitted). 7 In determining whether to grant leave under Rule 15, courts consider five factors: “bad 8 faith, undue delay, prejudice to the opposing party, futility of amendment, and whether the 9 plaintiff has previously amended the complaint.” United States v. Corinthian Colleges, 655 F.3d 10 984, 995 (9th Cir. 2011) (emphasis added). Among these factors, prejudice to the opposing party 11 carries the greatest weight. Eminence Capital, 316 F.3d at 1052. A proposed amendment is 12 futile “if no set of facts can be proved under the amendment to the pleadings that would 13 constitute a valid and sufficient claim or defense.” Gaskill v. Travelers Ins. Co., No. 11-cv- 14 05847-RJB, 2012 WL 1605221, at *2 (W.D. Wash. May 8, 2012) (citing Sweaney v. Ada

15 County, Idaho, 119 F.3d 1385, 1393 (9th Cir.1997)). 16 “If after removal the plaintiff seeks to join additional defendants whose joinder would 17 destroy subject matter jurisdiction, the court may deny joinder, or permit joinder and remand the 18 action to the State court.” 28 U.S.C. § 1447(e). The court should consider the following factors: 19 “(1) whether the party sought to be joined is needed for just adjudication and would be joined 20 under Federal Rule of Civil Procedure 19(a); (2) whether the statute of limitations would 21 preclude an original action against the new defendants in state court; (3) whether there has been 22 unexplained delay in requesting joinder; (4) whether joinder is intended solely to defeat federal 23 jurisdiction; (5) whether the claims against the new defendant appear valid; and (6) whether 24 1 denial of joinder will prejudice the plaintiff.” Falcon v. Scottsdale Ins. Co., No. CV-06-122-FVS, 2 2006 WL 2434227, at *2 (E.D. Wash. Aug. 21, 2006) (quoting IBC Aviation Servs., Inc. v. 3 Compania Mexicana de Aviacion, S.A. de C.V., 125 F. Supp. 2d 1008, 1011 (N.D. Cal. 2000)). 4 The Court will begin by analyzing the validity of Hale’s claims. If her claims are futile, 5 then she would not be prejudiced by denying leave to amend. If Hale’s claims are valid, then she

6 would likely be prejudiced if the Court forced her to file a separate lawsuit against Campbell- 7 VanDyke in state court. Hale asserts seven claims against Campbell-VanDyke: violation of the 8 Washington Consumer Protection Act (CPA), negligence, estoppel/promissory estoppel, breach 9 of fiduciary duty, failure to act in good faith, and negligent misrepresentation. Dkt. # 17-6 at 9- 10 11. 11 Hale premises her CPA claim on WAC 284-30-330 and “common law bad faith.” 12 Proposed FAC, Dkt. # 17-6, at 9. The Supreme Court of Washington recently held that WAC 13 284-30-330 cannot support a CPA claim against an individual employee of the insurer. Keodalah 14 v. Allstate Ins. Co., 194 Wash. 2d 339, 350 (2019). However, as this Court held in Leonard v.

15 First American Property & Casualty Insurance Co., No. 3:19-CV-06089-RBL, 2020 WL 16 634430, at *2 (W.D. Wash. Feb. 11, 2020), Keodalah does not extend to CPA claims based on 17 the common law duty of good faith. See also Zuniga v. Standard Guar. Ins. Co., No. C17- 18 5176RBL, 2017 WL 2266243, at *3 (W.D. Wash. May 24, 2017). There is no case clearly 19 barring such claims against employees of the insurer such as an insurance agent. Consequently, 20 the Court cannot say with certainty that a state court would dismiss Hale’s CPA claim against 21 Campbell-VanDyke and that it is therefore futile.

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
IBC Aviation Services, Inc. v. Compañia Mexicana De Aviacion
125 F. Supp. 2d 1008 (N.D. California, 2000)
Keodalah v. Allstate Ins. Co.
449 P.3d 1040 (Washington Supreme Court, 2019)
AAS-DMP Management, L.P. v. Acordia Northwest, Inc.
115 Wash. App. 833 (Court of Appeals of Washington, 2003)
Peterson v. Big Bend Insurance Agency
150 Wash. App. 504 (Court of Appeals of Washington, 2009)
Sweaney v. Ada County
119 F.3d 1385 (Ninth Circuit, 1997)
Carvalho v. Equifax Information Services, LLC
629 F.3d 876 (Ninth Circuit, 2010)

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Bluebook (online)
Hale v. Country Mutual Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hale-v-country-mutual-insurance-company-wawd-2020.