Happy Valley Road LLC v. Amguard Insurance Company

District Court, N.D. California·Decided September 21, 2023·No. 3:22-cv-06115·Unknown

Opinion

San Francisco Division HAPPY VALLEY ROAD LLC, Case No. 3:22-cv-06115-LB

Plaintiff, ORDER DISMISSING CASE v. Re: ECF No. 46

Defendant. The plaintiff, Happy Valley Road LLC, owns and rents high-end residential real estate in Orinda, California, primarily through short-term leases. The COVID-19 pandemic disrupted the short-term-rental market, resulting in lost rental income. The plaintiff submitted a claim for lost rental income for one property to its insurer, Amguard Insurance Company, alleging that the COVID-19 virus was a covered “direct physical loss.” Amguard denied the claim. The plaintiff then sued to recover its lost rental income. The court dismissed an earlier complaint claiming breach of contract and breach of the implied covenant of good faith and fair dealing because (1) a policy that covers “direct physical loss” does not cover losses incurred due to the COVID-19 pandemic, (2) the plaintiff did not allege the remaining requirements for coverage under the policy, and (3) the plaintiff did not plausibly plead Supreme Court decided the COVID-19 coverage question because — while that issue is dispositive — the plaintiff had not alleged other requirements for coverage and thus had not pleaded viable claims, even absent the COVID-19 coverage issue. The plaintiff filed an amended complaint, raising the same claims but alleging additional facts about its rental contract. The court dismisses the breach-of-contract claim with leave to amend by October 31, 2023, to correct fact errors about the rental contract. At that point, the plaintiff may renew its motion to stay. The court dismisses the breach-of-contract claim (to the extent it is predicated on the Civil Authority Prohibits Use coverage) and the bad-faith claim with prejudice because the plaintiff did not plausibly allege the claims or oppose Amguard’s motion to dismiss them. The plaintiff sued for its business losses on the ground that the presence of the virus on its property and elsewhere in Orinda, “and the resulting governmental orders, cause[d] ‘loss of use’ and ‘direct physical loss to property’ within the meaning of those phrases” in the insurance policy.1 The next sections excerpt the relevant policy terms and summarize new facts in the amended complaint. 1. The Policy The plaintiff contends that its loss is covered under the policy’s “Dwelling,” “Dwelling Rental Activities,” “Broadened Home-Sharing Host Activities,” and “Civil Authority Prohibits Use” coverages.2 The first three require a “direct physical loss” to the plaintiff’s property and the last requires direct physical loss to neighboring premises. (The policy does not contain a virus exclusion.) 1 Am. Compl. – ECF No. 43 at 6–7 (¶¶ 25–26). Citations refer to material in the Electronic Case File (ECF); pinpoint citations are to the ECF-generated page numbers at the top of documents. 1.1 Coverages Requiring Direct Physical Loss to the Plaintiff’s Premises The “Dwelling” coverage (Coverage A) covers “direct physical loss to property” and defines property as the insured’s dwelling on the “residence premises,” including attached structures.3 Under the “Dwelling Rental Coverage Endorsement” (Coverage D), the policy covers “lost rental value” if the insured has contracted with another person for “dwelling rental activities” for a specified period of time, and a “loss covered under Section I” (a “direct physical loss” to the property) “makes that part of the ‘residence premises’ used for such ‘dwelling rental activities’ not fit to live in during the period of time specified in such contract or agreement.” The loss is covered only if it occurs after the date of the rental agreement. Payments to the insured are for the lost rental value specified in the rental agreement, less any discontinued expenses, and they are paid “for the shortest period of time agreed upon” in the rental agreement.4 Under the “Broadened Home-Sharing Host Activities Coverage Endorsement” (Coverage D), the policy covers “lost rental value” if the insured has entered into an agreement for “home-sharing host activities” with another person through a “home-sharing network platform,” and a covered loss (“direct physical loss” to the property) “makes that part of the ‘residence premises’ . . . not fit to live in during the period of time specified in such contract or agreement.” Payments to the insured are for the lost rental value specified in the rental agreement, less any discontinued expenses, and they are paid for “the shortest period of time agreed upon” in the relevant agreement.5 1.2 Coverages Requiring Direct Physical Loss to Neighboring Premises The “Civil Authority Prohibits Use” coverage (Coverage D) provides that if a civil authority prevents the insured from using the “residence premises” “as a result of direct damage to neighboring premises by a Peril Insured Against, or due to an evacuation mandated by a civil authority that is caused by a covered peril,” then the policy covers “Fair Rental Value” for up to two

3 Policy, Ex. A to Kronenberg Decl. – ECF No. 9-1 at 25 (p. 22) (§ I.A.1(a)), 31 (p. 28) (§ I.A.1). Citations to the policy are first to the ECF number and then to the page number at the bottom center. 4 Id. at 75 (p. 72) (§ I.D.2(a)). weeks.6 Put more plainly, the policy pays the fair rental value for up to two weeks if a civil- authority order prohibits the plaintiff from using the property, the civil-authority order issues because of damage at a neighboring property, and the damage to the neighboring property was caused by “direct physical loss” to that property. Alternatively, the policy covers the rental value if the plaintiff is prohibited from using its property by an evacuation order issued as a result of “direct physical loss” to the neighboring property. 2. New Allegations in Amended Complaint The insured property is a home at 4134 Happy Valley Road in Orinda. It has six bedrooms and seven baths. It is used only as a rental property and is occupied only by rental guests.7 “Both requirements for Coverage D — Loss of Use[] coverage have been met. First[,] the named insured entered into a three-year contract with Rented.com to rent the . . . property for $17,600 per month” from August 20, 2018, through August 20, 2021.8 “On November 12, 2019, citing terms of the contract and the COVID-19 crisis, Rented.com cancelled that contract.”9 The plaintiff was unable to rent the property until June 22, 2020, and then only for three months for $15,000 per month.10 Second, “as indicated by the numerous government orders, as well as the cancellation of the contract by Rented.com, the COVID-19 crisis rendered the insured property . . . not fit to live in as required by the second prong of coverage.”11

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Happy Valley Road LLC v. Amguard Insurance Company, (N.D. Cal. 2023).

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