Houghton v. Allstate Property and Casualty Insurance Company

CourtDistrict Court, M.D. Louisiana
DecidedJuly 12, 2022
Docket3:19-cv-00695
StatusUnknown

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

Bluebook
Houghton v. Allstate Property and Casualty Insurance Company, (M.D. La. 2022).

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

CHARLES HOUGHTON CIVIL ACTION NO.

VERSUS 19-695-SDD-EWD

ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY, SENTINEL INSURANCE COMPANY, LTD., AND HARTFORD ACCIDENT & INDEMNITY COMPANY

RULING This matter is before the Court on the Cross-Motions for Partial Summary Judgment on Choice of Law filed by Plaintiff, Charles Houghton (“Houghton”)1 and by Defendant, Sentinel Insurance Company, LTD (incorrectly named as “Hartford Accident and Indemnity Company and/or Sentinel Insurance Company, LTD,” hereinafter “Sentinel”).2 Houghton and Sentinel filed Oppositions3 to the respective motions, and each filed a Reply.4 For the following reasons, the Court finds that Sentinel’s motion should be granted, and Houghton’s motion should be denied. I. FACTUAL BACKGROUND5 This case arises out of a collision which occurred on January 10, 2019 in Baton

1 Rec. Doc. No. 71. 2 Rec. Doc. No. 72. 3 Rec. Doc. Nos. 73 & 74. 4 Rec. Doc. Nos. 75 & 76 5 The following facts are admitted or deemed admitted unless otherwise indicated. Rouge, Louisiana involving Houghton and another driver.6 At the time of the accident, the 2018 GMC Sierra truck that Houghton was driving was owned by his employer, Advanced Industrial Resources, LLC (“AIR”).7 This vehicle was insured by a policy held by Sentinel numbered UEC KL9697 (“the policy”).8 The Sentinel policy was purchased by AIR.9 AIR’s insurance coverage with

Sentinel was exclusively placed by and through the Dickerson Agency,10 and Sentinel communicated with AIR via the Dickerson Agency.11 The Dickerson Agency first applied to Sentinel for insurance on behalf of AIR in 2010.12 On the insurance application written on behalf of AIR to Sentinel, Lisa Dickerson listed that AIR was seeking automobile liability coverage;13 and AIR was listed as being located in Marietta, Georgia.14 Also on the insurance application, there were six drivers listed, all of whom were licensed in Georgia, and there were eight vehicles listed, all listed as being garaged in Cartersville, Georgia.15 Each vehicle was listed as having an “intermediate” radius, which means that the vehicle would be driven a maximum of 200 miles from its garaging location in Cartersville, Georgia.16

6 Rec. Doc. No. 71-4, ¶ 7. 7 Id. at ¶ 5. 8 Rec. Doc. No. 74-9 – Certified Sentinel Policy (with premiums redacted) No. 20 UEC KL9697. 9 Rec. Doc. No. 74-9 – Certified Sentinel Policy No. 20 UEC KL9697, Bates No. “SENTINEL 54”. 10 Rec. Doc. No. 74-5 – Deposition of Nikolaus Baldwin, p. 101. 11 Rec. Doc. No. 74-4 – Deposition of Lisa Dickerson, p. 29, 44; Rec. Doc. No. 74-5 – Deposition of Nikolaus Baldwin, p. 101; Rec. Doc. No. 74-6 – Deposition of Scott Wilson, p. 17. 12 Rec. Doc. No. 74-4 – Deposition of Lisa Dickerson, p. 17. 13 Id. at p. 26; Rec. Doc. No. 74-8 - Declaration of Nikolaus Baldwin and attachments (with premiums, license numbers, and birthdates redacted) and Exhibit A attached thereto. 14 Rec. Doc. No. 74-8 - Declaration of Nikolaus Baldwin and attachments (with premiums, license numbers, and birthdates redacted) and Exhibit A attached thereto. 15 Id. 16 Rec. Doc. No. 74-4 – Deposition of Lisa Dickerson, p. 24 – 25; Rec. Doc. No. 74-5 – Deposition of Nikolaus Baldwin p. 97; Rec. Doc. No. 74-8 - Declaration of Nikolaus Baldwin and attachments (with premiums, license numbers, and birthdates redacted) and Exhibit A attached thereto. On December 14, 2010, Sentinel bound and later issued the original AIR auto policy based upon the information provided by AIR’s agent in the insurance application.17 Sentinel contends it complied with Georgia law in binding and issuing the policy.18 The policy did not include forms specific to any state apart from Georgia;19 it charged a premium based upon the risk Sentinel was insuring in Georgia;20 it was a scheduled policy

(not a fleet policy) that specifically listed each vehicle covered under the policy;21 and it stated that it provided $100,000 in UMBI coverage.22 Every year from the inception of the Sentinel policy in 2010 to the policy issued in 2018, the Sentinel auto coverage was renewed.23 Every year at renewal of the Sentinel policy, the Dickerson Agency would inform Sentinel of any changes or additions to the policy.24 Sentinel claims that, although new drivers were periodically added to the policy, all drivers were consistently listed as licensed in Georgia.25 It is undisputed that, while

17 Rec. Doc. No. 74-5 – Deposition of Nikolaus Baldwin, p. 38, 40 – 41. 18 Id. at pp. 42-43, 52, 93. Houghton denies this fact based on a legal argument and his insistence that the policy itself required the return of a signed form in writing. See Rec. Doc. No. 73-1, ¶ 15 (quoting Rec. Doc. No. 71-6, p. 15 (Sentinel Insurance Policy No. 20 UEC KL9697). 19 Rec. Doc. No. 74-9 - Certified Sentinel Policy No. 20 UEC KL9697. 20 Rec. Doc. No. 74-5 – Deposition of Nikolaus Baldwin, pp. 42, 52, 93. Houghton denies this statement citing to the Policy Adjustment Notice which, it claims, “suggests that Sentinel charged AIR, LLC a premium based on estimates and assumptions related to ‘payroll, sales revenue, and the nature of business operations for the policy period shown.’” Rec. Doc. No. 73-1, ¶ 17 (quoting Rec. Doc. No. 71-6, p. 52 (Sentinel Insurance Policy No. 20 UEC KL9697). 21 Rec. Doc. No. 74-9 - Certified Sentinel Policy No. 20 UEC KL9697, Bates No. “Sentinel 54, 63, 78”. Houghton denies this statement “for lack of information to the extent that the term “scheduled policy” is a term of art used by the insurance industry.” Rec. Doc. No. 73-1, ¶ 18. Houghton does not cite record evidence to counter Sentinel’s statement. 22 Rec. Doc. No. 74-9 - Certified Sentinel Policy No. 20 UEC KL9697, Bates No. “Sentinel 64”. Houghton admits this statement but adds that he denies it “to the extent that the Georgia Uninsured Motorists Coverage Selection /Rejection form is blank.” Rec. Doc. No. 73-1, ¶ 19 (citing Rec. Doc. No. 71-6, p. 15- 18 (Sentinel Insurance Policy No. 20 UEC KL9697). 23 Rec. Doc. No. 74-4 – Deposition of Lisa Dickerson, p. 151; Rec. Doc. No. 74-5 – Deposition of Nikolaus Baldwin, p. 81. Houghton denies that the policy at issue was “automatically” renewed. Rec. Doc. No. 73- 1, ¶ 20 (citing Rec. Doc. No. 71-6, pp. 15-18 (Sentinel Insurance Policy No. 20 UEC KL9697); Rec. Doc. No. 72-4, pp. 69-74. 24 Rec. Doc. No. 74-4 – Deposition of Lisa Dickerson, pp. 130 – 131 25 Id. at pp. 61, 155; Rec. Doc. No. 74-8 - Declaration of Nikolaus Baldwin and attachments (with premiums, license numbers, and birthdates redacted). Houghton denies this allegation for lack of information and argues that, for the 2018-2019 policy in effect on the date of this collision, Sentinel did not request an new vehicles were periodically added to the Sentinel policy, all vehicles were always listed as garaged and registered in Cartersville, Georgia,26 and all vehicles were always listed as having a travel radius of no more than 50 to 200 miles from their Cartersville, Georgia garage locations.27 AIR opened a Louisiana location in either 2017 or 2018.28 It is undisputed that,

before Houghton’s accident, Sentinel was not advised by AIR that it had an office in Louisiana.29 Before the January 10, 2019 accident, Sentinel contends it had no knowledge that AIR had an office in Louisiana.30 Around March 8, 2018, AIR informed the Dickerson Agency that it had purchased the 2018 GMC Sierra which was involved in the subject accident.31 In response, the Dickerson Agency sent a change form to Sentinel advising that AIR wished to have the 2018 GMC Sierra added to the Sentinel policy.32 On the change form, the Dickerson Agency informed Sentinel that the 2018 GMC Sierra was registered in Georgia.33 However, on the change form, the Dickerson Agency also informed Sentinel that the 2018

updated driver’s list before automatically renewing the policy.

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Houghton v. Allstate Property and Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/houghton-v-allstate-property-and-casualty-insurance-company-lamd-2022.