Huey v. Allstate Vehicle and Property Insurance Company

District Court, N.D. Mississippi·Decided September 8, 2020·No. 4:19-cv-00153·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI GREENVILLE DIVISION FILLISA HUEY, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED PLAINTIFFS Vv, CIVIL ACTION NO. 4:19-CV-00153-GHD-JMV ALLSTATE VEHICLE AND PROPERTY INSURANCE COMPANY DEFENDANT

OPINION DENYING MOTION TO DISMISS AND LIFTING STAY OF PROCEEDINGS Presently before the Court in this putative class action insurance dispute is the Defendant’s Amended Motion to Dismiss pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure [15, 30]. Upon due consideration and as set forth below, the Court finds that the motion should be denied. Further, the Court shall lift the stay of proceedings that was entered in this matter on January 29, 2020 [27, 29]. 1, Factual and Procedural Background! The Plaintiff, Fillisa Huey, maintains a residence in Cleveland, Mississippi. [First Amended Class Action Complaint, Doc. No. 14, at 1]. Huey insured the residence under a Homeowners Policy, No. 810268968, written by the Defendant Allstate Vehicle and Property Insurance Company, and paid the requisite annual premiums for the coverage. [/d. at 2]. The policy provides, inter alia, that payment for covered loss may be for “Actual Cash Value,” (“ACV”), which may include a deduction for depreciation of certain costs. [/d, at 3]. In February 2017, while insured under the policy, Plaintiffs residence suffered direct

1 On a Rule 12(b)(6) motion to dismiss, the Court accepts all well-pleaded facts in the complaint as true and views those facts in the light most favorable to the Plaintiff. Randall D, Wolcoft, M.D, P.A, y. Sebelius, 635 F.3d 757, 763 (Sth Cir. 2011),

physical damage by a covered named peril. [/d.] The Plaintiff immediately notified the Defendant of the loss and made a claim under the insurance policy. [/d.] The Defendant inspected the Plaintiff's residence and determined that the loss was covered under the insurance policy. [/d.] On February 16, 2017, the Defendant notified the Plaintiff that the payment she was receiving was the ACV as calculated by Defendant. [/d. at 3-4]. In calculating the Plaintiff's ACV payment, the Defendant deducted depreciation from the replacement cost value (RCV).? [d.] The Plaintiff alleges that Defendant’s method of calculating the ACV resulted in a payment amount that is lower than the amount Plaintiff should have received under the Policy. [/d. at 4]. The Plaintiff argues that Defendant, in calculating the ACV, depreciated costs associated with labor; the Plaintiff asserts that labor should not be depreciated because it does not depreciate in value over time and because the policy language is ambiguous regarding the depreciation of labor costs. jd. at 4-5], Based on Defendant’s alleged practice of depreciating labor costs, the Plaintiff avers that her ACV payment was less than the amount she was entitled to receive under the policy, and that the Defendant thus breached its obligations under the policy, The Plaintiff filed her Complaint in this matter on October 11, 2019 [1]; she then filed an Amended Complaint on January 3, 2020 [14]. In the Amended Complaint, the Plaintiff alleges that the Defendant breached its contractual duty to pay Plaintiff and members of the proposed class the true ACY of their claims by wrongfully depreciating labor costs (Count [); the Plaintiff also seeks a declaratory judgment decreeing that the policy, as written, prohibits the Defendant from depreciating labor costs when calculating losses and ACV (Count IT). Pursuant to Federal Rule of Civil Procedure 12(b)(6), the Defendant now moves to dismiss Plaintiff's entire complaint.

2 The Defendant calculated that the Replacement Cost Value of the Plaintiff's property was $164,202.86; it reduced the value by $31,471.42 for depreciation. [/d. at 4].

.

If. Rule 12(b)(6} Motion to Dismiss Standard When deciding a Rule 12(b)(6) motion to dismiss, the Court is limited to the allegations set forth in the complaint and any documents attached to the complaint. Walker vy. Webco Indus., 562 F. App’x 215, 216-17 (Sth Cir, 2014) (citing Kennedy vy. Chase Manhattan Bank USA, NA, 369 F.3d 833, 839 (5th Cir. 2004)). “[A plaintiffs] complaint therefore ‘must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.’” Phillips v. City of Dallas, Tex., 781 F.3d 772, 775-76 (Sth Cir. 2015) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678, 1298, Ct: 1937, 173 L. Ed. 2d 868 (2009)). A claim is facially plausible when the pleaded factual content “allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” /gbal, 556 U.S. at 678, 129 S. Ct. 1937 (citing Bell Atl. Corp. v. Twombly, 550 U.S, 544, 556, 127 S. Ct. 1955, 167 L, Ed. 2d 929 (2007)). “[PHlaintiffs must allege facts that support the elements of the cause of action in order to make out a valid claim.” Webb vy. Morelia, 522 F. App’x 238, 241 (Sth Cir. 2013) (quoting City of Clinton, Ark. v. Pilgrim’s Pride Corp., 632 F.3d 148, 152-53 (Sth Cir. 2010) (internal quotation marks omitted)). “[C]onclusory allegations or legal conclusions masquerading as factual conclusions will not suffice to prevent a motion to dismiss,” /d (quoting Fernandez— Montes y. Allied Pilots Ass’n, 987 F.2d 278, 284 (Sth Cir. 1993) Gnternal quotation marks omitted)). “Dismissal is appropriate when the plaintiff has not alleged ‘enough facts to state a claim to relief that is plausible on its face’ and has failed to ‘raise a right to relief above the speculative level.” Emesowum v. Houston Police Dep’t, 561 F, App’x 372, 372 (Sth Cir, 2014) (quoting Twombly, 550 U.S. at 555, 570, 127 S. Ct. 1955),

HL. Analysis? A. Claim for Breach of Contract (Count D The Plaintiff asserts that the Defendant breached the parties’ contract of insurance by depreciating the value of labor in determining the amount of the Plaintiff's ACV payment under the policy, [Doc. 14, at 4]. Assuming the facts in the complaint are true and construing them in the light most favorable to the Plaintiff, the Court finds that the Plaintiff has sufficiently pled a breach of contract claim, “Mississippi treats insurance policies as contracts, which ‘are to be enforced according to their provisions.’” State Farm Mut. Auto, Ins, Co, v. LogistiCare Solutions, LLC., 751 F.3d 684, 688 (Sth Cir. 2014) (quoting Noxubee Cnty. Sch. Dist. v. United Nat'l Ins. Co., 883 So0.2d 1159, 1166 (Miss. 2004)), A contract “must be interpreted as written” only if it is “clear and unambiguous.” State Farm Mut. Auto. Ins. Co. v. LogistiCare Solutions, LLC., 751 F.3d 684, 688 (5th Cir. 2014) (quoting Fid. & Guar. Co. of Miss. v. Martin, 998 So.2d 956, 963 (Miss. 2008)), Ambiguity exists when the “policy language is susceptible of two or more reasonable interpretations.” Miss. Farm Bureau Cas, Ins. v. Britt, 826 So.2d 1261, 1265 (Miss. 2002).

Free access — add to your briefcase to read the full text and ask questions with AI

Huey v. Allstate Vehicle and Property Insurance Company, (N.D. Miss. 2020).

Huey v. Allstate Vehicle and Property Insurance Company (Huey v. Allstate Vehicle and Property Insurance Company) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Kennedy v. Chase Manhattan Bank USA, NA
369 F.3d 833 (Fifth Circuit, 2004)
Audler v. CBC Innovis Inc.
519 F.3d 239 (Fifth Circuit, 2008)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
City of Clinton, Ark. v. Pilgrim's Pride Corp.
632 F.3d 148 (Fifth Circuit, 2010)
RANDALL D. WOLCOTT, MD, PA v. Sebelius
635 F.3d 757 (Fifth Circuit, 2011)
Belva Webb v. Joseph Morella
522 F. App'x 238 (Fifth Circuit, 2013)
Mississippi Farm Bureau Cas. Ins. Co. v. Britt
826 So. 2d 1261 (Mississippi Supreme Court, 2002)
Harrison v. Allstate Ins. Co.
662 So. 2d 1092 (Mississippi Supreme Court, 1995)
Noxubee Co. Sch. Dist. v. United Nat. Ins.
883 So. 2d 1159 (Mississippi Supreme Court, 2004)
Blackledge v. Omega Ins. Co.
740 So. 2d 295 (Mississippi Supreme Court, 1999)
Conner v. American Public Life Insurance
448 F. Supp. 2d 762 (N.D. Mississippi, 2006)
Redcorn v. State Farm Fire & Casualty Co.
2002 OK 15 (Supreme Court of Oklahoma, 2002)
Freddie Walker, Sr. v. Webco Industries, Incorpora
562 F. App'x 215 (Fifth Circuit, 2014)
Micah Phillips v. City of Dallas
781 F.3d 772 (Fifth Circuit, 2015)
Henn v. American Family Mut. Ins. Co.
894 N.W.2d 179 (Nebraska Supreme Court, 2017)
Business Communications, Inc. v. Banks
90 So. 3d 1221 (Mississippi Supreme Court, 2012)