Harborside of Dayton Ltd. Partnership v. Safety Natl. Cas. Corp.

2023 Ohio 4562
CourtOhio Court of Appeals
DecidedDecember 15, 2023
Docket29621
StatusPublished

This text of 2023 Ohio 4562 (Harborside of Dayton Ltd. Partnership v. Safety Natl. Cas. Corp.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harborside of Dayton Ltd. Partnership v. Safety Natl. Cas. Corp., 2023 Ohio 4562 (Ohio Ct. App. 2023).

Opinion

[Cite as Harborside of Dayton Ltd. Partnership v. Safety Natl. Cas. Corp., 2023-Ohio-4562.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

HARBORSIDE OF DAYTON LIMITED : PARTNERSHIP et al. : : C.A. No. 29621 Appellants : : Trial Court Case No. 2019 CV 05584 v. : : (Civil Appeal from Common Pleas SAFETY NATIONAL CASUALTY : Court) CORPORATION et al. : : Appellees

...........

OPINION

Rendered on December 15, 2023

QUINTIN F. LINDSMITH, JENNIFER G. COOPER & ANDREW ROACH, Attorneys for Appellee

MARK J. KESSLER, LAWRENCE BLUESTONE, & LAUREN GERSHUNY, Attorneys for Appellant

.............

LEWIS, J.

{¶ 1} Plaintiffs-Appellants Harborside of Dayton Limited Partnership

(“Harborside”), Sun Healthcare Group, Inc. (“Sun”), and Genesis Healthcare LLC

(“Genesis”) (collectively, “the Plaintiffs”) appeal from an order of the Montgomery County -2-

Common Pleas Court granting summary judgment to Defendant-Appellee Broadspire

Services, Inc. (“BSI”). For the following reasons, we will affirm the judgment of the trial

court.

I. Facts and Course of Proceedings

{¶ 2} This appeal involves the handling of a worker’s compensation claim by self-

insured employers, their third-party administrators, and their excess insurance carrier. In

2006, Harborside operated a long-term care facility in Dayton known as Forest View Care

and Rehabilitation Center. A.C.W. was hired by Harborside as a director of nursing.1

On August 8, 2006, A.C.W. was injured when she tripped and fell at Harborside’s facility

while in the scope of her employment. A.C.W. filed a workers’ compensation claim and

was granted temporary disability benefits.

{¶ 3} At the time A.C.W. was injured, Harborside had a contract with Corvel, a

third-party administrator, to assist it with handling its workers’ compensation claims. As

a self-insured employer, Harborside had procured an excess insurance policy with Safety

National Casualty Corporation (“Safety National”), which was in effect for the period

during which A.C.W. was injured. The insurance policy provided that Safety National

would be obligated to pay for the costs of a workers’ compensation claim that exceeded

Harborside’s self-insured retention (“SIR”) amount of $500,000 and Harborside would be

responsible for paying any costs up to $500,000. Further, Harborside was required to

provide prompt notice of a claim to Safety National when the claim had exceeded or was

1 To protect the privacy of the injured employee, we will use initials rather than her name. -3-

likely to exceed 50% of the SIR (i.e., $250,000) or when the injured employee’s disability

exceeded one year in duration or appeared reasonably likely to exceed one year in

duration.

{¶ 4} In October 2006, Sun acquired Harborside. At that time, Sun was insured

under an excess policy issued by a subsidiary of AIG for the policy term of April 1, 1998

through December 31, 2009. The SIR amount under the AIG policy was $1,000,000.

Therefore, under the AIG policy, Sun would be responsible for paying the first $1,000,000

on any claim covered by the excess policy, and AIG would take over financial

responsibility for any amounts exceeding that threshold.

{¶ 5} The cost of A.C.W.’s claim increased over time as A.C.W.’s condition

worsened. For example, A.C.W. was granted an allowable condition of a lumbar strain

with sciatica on December 15, 2006, was granted temporary total benefits effective March

6, 2007, and underwent a neurosurgery evaluation in February 2009. As of February

2009, the total amount paid on A.C.W.’s claim was $126,523, and there was the possibility

that future spinal surgery would be necessary.

{¶ 6} Corvel initially provided information to Safety National about the A.C.W. claim

and its increasing costs. But Safety National typically did not set up its own claim file

until the costs of the claim reached at least one-half the SIR amount under the excess

policy. On June 1, 2009, BSI took over for Corvel as the third-party administrator for

Sun’s workers’ compensation claims, including A.C.W.’s claim. Angela Love, an

employee of Safety National during the relevant period, stated that Safety National

received the last loss-run report from Corvel in March 2009 but did not reach out to Corvel -4-

again for further information on the A.C.W. claim until September 2011. At that time,

Safety National first became aware of the change in Sun’s third-party administrators from

Corvel to BSI. According to Janice Burnap, the Director of Risk and Insurance Services

for Sun (and later, Genesis), it was Sun’s responsibility to notify Safety National about

any change in Sun’s third-party administrator.

{¶ 7} The amount of A.C.W.’s claim continued to grow, and attempts to settle the

claim proved unsuccessful. By October 2010, the A.C.W. claim exceeded 50% of the

$500,000 SIR under the Safety National excess insurance policy. Just a year later, on

October 6, 2011, the incurred amount on the A.C.W. claim exceeded $500,000.

{¶ 8} On February 17, 2012, Maggie Smith, Senior Claims Analyst for Safety

National, sent a letter to BSI asking it to complete and return an attached first report form

relating to A.C.W. The letter noted that “[a] review of the most recent 2012 workers’

compensation loss experience report” for the A.C.W. claim showed that the claim needed

to be reported to Safety National, because the total incurred “exceeded 50% of the Self-

Insured Retention Level.” According to the letter, “the total incurred shown is $521,177

the S.I.R. is $500,000.” On April 2, 2012, Linda Mullans, an employee of Safety National,

sent an email to Vicky Hardie at BSI requesting the first report update. Hardie emailed

the first report and supporting documentation to Linda Mullans on April 6, 2012.

{¶ 9} Maggie Smith, on behalf of Safety National, then authored an August 30,

2012 Reservation of Rights (“ROR”) letter addressed to Hardie at BSI. In the letter,

Smith acknowledged receipt of the initial report relating to the A.C.W. claim. Smith then

referred to the language in the excess insurance policy. Smith explained, in part: -5-

The file should have been reported to us previously based on the fact

the lost time exceeded one year and the total incurred exceeded 50% of the

self insured retention. The late report is in violation of Section I of the

Insurance Agreement.

Failure to report the claim to Safety National on a timely basis also

denied us the opportunity to participate in the defense of this claim, which

is provided under Section J of the Insurance Agreement.

The claimant underwent surgery in November of 2010. Per the

information received it appears her surgery was not litigated. * * * This is

a potential violation of Section K of the Insurance Agreement.

* * * Failure to reasonable [sic] attempt to settle this claim is another

potential violation of Section K of the Insurance Agreement.

Lastly, Section U states, in part, that full compliance by the Employer

with all terms of this agreement is a condition precedent to the Corporation’s

liability hereunder. As noted above there are violations to this agreement,

which in turn would be a violation of this section of the agreement.

{¶ 10} Smith then concluded her letter with the following reservation of rights

language:

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