Hilario v. Allstate Insurance Company

CourtDistrict Court, N.D. California
DecidedDecember 23, 2020
Docket3:20-cv-05459
StatusUnknown

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

Bluebook
Hilario v. Allstate Insurance Company, (N.D. Cal. 2020).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 TISHA HILARIO, Case No. 20-cv-05459-WHO

8 Plaintiff, ORDER GRANTING DEFENDANT'S 9 v. MOTION TO DISMISS

10 ALLSTATE INSURANCE COMPANY, Dkt. No. 19 Defendant. 11

12 13 INTRODUCTION 14 Plaintiff Tisha Hilario brings this action on behalf of herself and a putative class of 15 California home insurance policyholders against defendant Allstate Insurance Company 16 (“Allstate”), challenging Allstate’s alleged method for calculating a home’s square footage. She 17 alleges that Allstate improperly double counts the square footage of policyholders’ garages when 18 determining the total square footage of a property and charges policyholders inflated premiums 19 based on these incorrect figures. She brings claims for (i) breach of contract; (ii) breach of the 20 implied warranty of good faith and fair dealing; and (iii) violation of Cal. Bus. & Prof. Code § 21 17200, et seq. (the “UCL”). 22 Allstate moves to dismiss all three of her claims for failure to state a claim under Rule 23 12(b)(6). As discussed in detail below, Hilario’s contract-based claims fail because she alleges 24 misconduct that predates any alleged contractual obligation. Her UCL claim, which sounds in 25 fraud, fails to meet the heightened particularity requirements of Rule 9(b). For these reasons, 26 Allstate’s motion to dismiss GRANTED. Hilario will have 30 days leave to amend. 27 1 BACKGROUND 2 I. HILARIO’S INSURANCE POLICY 3 Plaintiff Tisha Hilario is a San Francisco resident and homeowner. Dkt. No. 1, (“Compl.”) 4 ¶ 3. Her home has been covered by an Allstate homeowners insurance policy since at least 5 February 2020, under policy number 914140656. Id.; Compl., Ex. A. Hilario alleges that Allstate 6 overcharged her by using an incorrect, inflated square footage of her home to calculate her home 7 insurance premiums. Compl. ¶ 21. Specifically, Hilario alleges that the correct square footage of 8 her home is 1154 square feet, comprising 862 square feet of total finished living space and 288 9 square feet from an attached single-car garage. Id. ¶¶ 20-21. However, Hilario’s insurance policy 10 lists the square footage of her home as 1438 square feet. Id. ¶ 19. She asserts that Allstate double 11 counted the 288 square feet of garage space when calculating the total square footage of her home 12 to reach this allegedly incorrect 1438 square feet figure. Id. ¶¶ 19-21. 13 On information and belief, Hilario alleges that since at least January 2019, Allstate has 14 been systematically overcharging California policyholders by knowingly double counting garage 15 space when calculating the total square footage used to determine their home insurance premiums 16 and CEA earthquake policy premiums. Id. ¶¶ 1, 16-17. 17 II. POLICY DISCLOSURES 18 Hilario’s homeowners insurance policy contains several statements relevant to this 19 litigation. On the first page of the insurance policy a bolded paragraph in the right-hand margin 20 states: 21 Some of all of the information on your Policy Declarations is used in the rating of your policy or it could affect your eligibility for certain coverages. Please notify us 22 immediately if you believe that any information on your Policy Declarations is incorrect. We will make corrections once you have notified us, and any resulting 23 rate adjustments, will be made only for the current policy period or for future policy periods. Please also notify us immediately if you believe any coverages are 24 not listed or are inaccurately listed. 25 Compl., Ex. A, Policy Declarations at 1. In addition, the policy section titled “Coverage 26 Changes” states, in part: 27 The coverage provided and the premium for the policy is based on information you incomplete, we may adjust your coverage premium accordingly during the policy 1 period. 2 Compl., Ex. A, Policy at 4. Near the end of the policy, a section titled “Suit Against Us” 3 states: 4 No suit or action can be brought against us unless there has been full compliance with all the terms of this policy. 5 Id. at 24. 6 III. HILARIO’S CLAIMS 7 Hilario brings this action individually and on behalf of a putative class of California 8 Allstate home insurance policyholders who have at least one garage. Compl. ¶ 1. She brings 9 claims for (i) breach of contract; (ii) breach of implied covenant of good faith and fair dealing; and 10 (iii) unlawful or unfair business practices under Cal. Bus. & Prof. § 17200, et seq. 11 All of Hilario’s claims are brought on behalf of a putative class which Hilario seeks to 12 define as: 13 All Allstate California policyholders from August 5, 2016 to the present with at least 14 one built-in garage who paid premiums for homeowners or renters insurance to Allstate. 15 Id. at ¶ 23. She also seeks to represent one sub-class defined as: 16 All class members who had earthquake coverage in California. 17 Id. 18 LEGAL STANDARD 19 Under Federal Rule of Civil Procedure 12(b)(6), a district court must dismiss a complaint 20 if it fails to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). To survive a 21 Rule 12(b)(6) motion to dismiss, the plaintiff must allege “enough facts to state a claim to relief 22 that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556 (2007). A claim is 23 facially plausible when the plaintiff pleads facts that “allow the court to draw the reasonable 24 inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 25 678 (2009) (citation omitted). There must be “more than a sheer possibility that a defendant has 26 acted unlawfully.” Id. While courts do not require “heightened fact pleading of specifics,” a 27 plaintiff must allege facts sufficient to “raise a right to relief above the speculative level.” 1 Twombly, 550 U.S. at 555, 570. However, under Federal Rule of Civil Procedure 9(b), a party 2 must “state with particularity the circumstances constituting fraud or mistake,” including “the 3 who, what, when, where, and how of the misconduct charged.” Vess v. Ciba-Geigy Corp. USA, 4 317 F.3d 1097, 1106 (9th Cir. 2003) (internal quotation marks omitted). “Rule 9(b) requires only 5 that the circumstances of fraud be stated with particularity; other facts may be pleaded generally, 6 or in accordance with Rule 8.” United States ex rel. Lee v. Corinthian Colls., 655 F.3d 984, 992 7 (9th Cir. 2011). 8 In deciding a motion to dismiss for failure to state a claim, the court accepts all of the 9 factual allegations as true and draws all reasonable inferences in favor of the plaintiff. Usher v. 10 City of Los Angeles, 828 F.2d 556, 561 (9th Cir. 1987). But the court is not required to accept as 11 true “allegations that are merely conclusory, unwarranted deductions of fact, or unreasonable 12 inferences.” In re Gilead Scis. Sec. Litig., 536 F.3d 1049, 1055 (9th Cir. 2008).

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Hilario v. Allstate Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hilario-v-allstate-insurance-company-cand-2020.