James Hamilton Properties, LLC v. Great Midwest Insurance Company

CourtDistrict Court, E.D. Kentucky
DecidedApril 28, 2022
Docket7:21-cv-00095
StatusUnknown

This text of James Hamilton Properties, LLC v. Great Midwest Insurance Company (James Hamilton Properties, LLC v. Great Midwest Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Hamilton Properties, LLC v. Great Midwest Insurance Company, (E.D. Ky. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY SOUTHERN DIVISION AT PIKEVILLE

CIVIL ACTION NO. 21-95-DLB

JAMES HAMILTON PROPERTIES, LLC PLAINTIFF

v. MEMORANDUM ORDER

GREAT MIDWEST INSURANCE CO., et al. DEFENDANTS

*** *** *** *** This matter is before the Court upon Plaintiff James Hamilton Properties, LLC’s Motion to Remand this case to Pike Circuit Court (Doc. # 8). The Motion has been fully briefed (Docs. # 10 and 11) and is ripe for review. For the reasons stated herein, Plaintiff’s Motion to Remand (Doc. # 8) is DENIED. I. FACTUAL AND PROCEDURAL BACKGROUND On October 27, 2021, Plaintiff James Hamilton Properties, LLC (“James Hamilton”) filed suit against Defendants Great Midwest Insurance Company (“Great Midwest”) and Complete Insurance, LLC (“Complete Insurance”) in Pike Circuit Court alleging a number of claims related to an insurance claim made by James Hamilton. (Doc. # 1-1). Plaintiff secured an insurance policy from Great Midwest that allegedly covered property damage on Plaintiff’s coal crushing and coal screening plants. (Id. ¶ 10). Plaintiff procured the policy by contracting with Defendant Complete Insurance, which is an insurance agency. (Id. ¶¶ 7, 54). On October 30, 2019, a fire and/or act of vandalism occurred at Plaintiff’s coal crushing and coal screening plant located in Pikeville, Kentucky. (Id. ¶ 9). Plaintiff alleges that the policy it procured for property damage covers up to $275,000 “against various losses including fire, vandalism and other losses to the property/equipment described above.” (Id. ¶ 11). Defendant Great Midwest allegedly breached this policy by failing to pay for all of the property damage incurred at the coal crushing and screening plant. (Id. ¶ 10). According to Plaintiff, Great Midwest offered $14,250 to cover the damages,

instead of the complete appraisal value of $268,000. (Id. ¶¶ 20-21). Plaintiff asserts that Great Midwest is arguing that only two pieces of Plaintiff’s equipment were covered by Plaintiff’s insurance policy, while the other damaged property was excluded from coverage. (Doc. # 8-1 at 2). Great Midwest instead argues that it is simply disputing the value of Plaintiff’s claim. (Doc. # 10 at 1-2). The only claim alleged against Complete Insurance is that it breached its contract with Plaintiff by not “provid[ing] adequate insurance coverage . . . for all Plaintiff’s coal crushing and coal screening plants and equipment thereby leaving Plaintiff not properly insured as to the events/claims stated herein.” (Id. ¶ 53).

II. ANALYSIS A. Standard of Review Under 28 U.S.C. § 1441(a), “any civil action brought in a state court of which the district courts of the United States have original jurisdiction, may be removed by the defendant or defendants, to the district court of the United States for the district and division embracing the place where such action is pending.” Removal statutes are to be narrowly construed, as they were “adopted in order to restrict rather than expand the scope of removal from the state courts.” First Nat’l Bank of Pulaski v. Curry, 301 F.3d 456, 464 (6th Cir. 2002). Accordingly, “all doubts as to the propriety of removal are resolved in favor of remand.” Coyne ex rel. Ohio v. Am. Tobacco Co., 183 F.3d 488, 493 (6th Cir. 1999). Here, removing Defendants argue that this Court has diversity jurisdiction under 28 U.S.C. § 1332(a)(1). (Doc. # 1 at 5). B. Diversity Jurisdiction and Fraudulent Joinder Section 1332 confers on district courts “original jurisdiction of all civil actions where

the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs, [] and is between citizens of different states.” Section 1332 requires complete diversity between a plaintiff and all defendants.1 Coyne v. Am. Tobacco Co., 183 F.3d 488, 492 (6th Cir. 1999). In other words, “[d]iversity jurisdiction attaches only when all parties on one side of the litigation are of a different citizenship from all parties on the other side of the litigation.” Id. (quoting SHR Ltd. P’ship v. Braun, 888 F.2d 455, 456 (6th Cir. 1989)). Here, Plaintiff is a “resident” of Kentucky. (Doc. # 1-1 ¶ 1). Defendant Complete Insurance is a Kentucky LLC, with its principal place of business in Pikeville, Kentucky,

also resides in Kentucky for diversity purposes. (Docs. # 1-1 ¶ 3 and 10-2). Defendant Great Midwest is a Texas corporation, and therefore considered a resident of Texas for diversity purposes. (Id. ¶ 2). Based on the complete diversity rule, if Defendant Complete Insurance is a proper party to this action, then Plaintiff’s Motion to Remand must be granted. While Plaintiff argues that Complete Insurance is a proper party (Doc. # 8-1 at 3- 9), Great Midwest argues that Complete Insurance has been fraudulently joined in order

1 Plaintiff acknowledges in its Motion to Remand that the amount in controversy exceeds the jurisdictional requirements for diversity jurisdiction. (Doc. # 8-1 at 3). Therefore, the only remaining issue is whether the complete diversity requirement is met. to defeat complete diversity. (Doc. # 10 at 5-23). “[F]raudulent joinder of non-diverse defendants will not defeat removal on diversity grounds.” Coyne, 183 F.3d at 493. The removing party has the burden of presenting “sufficient evidence that a plaintiff could not have established a cause of action against non-diverse defendants under state law.” Id. The relevant question “is whether there is arguably a reasonable basis for predicting that

the state law might impose liability on the facts involved.” Alexander v. Electr. Data Sys. Corp., 13 F.3d 940, 949 (6th Cir. 1994) (quoting Bobby Jones Garden Apartments, Inc. v. Suleski, 391 F.2d 172, 176 (5th Cir. 1968)). This test has been characterized as “more lenient than [] the analysis applicable to a Rule 12(b)(6) motion to dismiss.” Casias v. Wal-Mart Stores, Inc., 695 F.3d 428, 433 (6th Cir. 2012) (citing Walker v. Phillip Morris USA, Inc., 443 F. App’x 946, 952-54 (6th Cir. 2011)). Based on the record available to the Court, it finds that Plaintiff is currently unable to establish a cause of action against Complete Insurance. In its Complaint, Plaintiff asserts a single cause of action against Complete Insurance—breach of contract. (Doc.

# 1-1 ¶¶ 53-55). Specifically, Plaintiff alleges that Complete Insurance breached its contract to secure an insurance policy that provided adequate coverage of Plaintiff’s assets. (Id.). Defendant Great Midwest argues that Plaintiff’s claim against Complete Insurance “for the alleged failure to procure insurance for all equipment . . . is not viable” because Complete Insurance did obtain coverage for the equipment under the Policy. (Doc. # 10 at 1-2). Alternatively, Great Midwest argues that the claim against Complete Insurance is not ripe because the existence of Plaintiff’s claim against Complete Insurance “is contingent upon the outcome of the claim against [Great Midwest].” (Id. at 2).2 C.

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

Related

Texas v. United States
523 U.S. 296 (Supreme Court, 1998)
John Walker v. Philip Morris USA Inc.
443 F. App'x 946 (Sixth Circuit, 2011)
Coyne v. The American Tobacco Company
183 F.3d 488 (Sixth Circuit, 1999)
Joseph Casias v. Wal-Mart Stores, Inc.
695 F.3d 428 (Sixth Circuit, 2012)
Dealer Computer Services, Inc. v. Dub Herring Ford
547 F.3d 558 (Sixth Circuit, 2008)
Conestoga Chemical Corp. v. F. H. Simonton, Inc.
269 A.2d 237 (Supreme Court of Delaware, 1970)
Grigsby v. Mountain Valley Insurance Agency, Inc.
795 S.W.2d 372 (Kentucky Supreme Court, 1990)
Plaza Bottle Shop, Inc. v. Al Torstrick Insurance Agency, Inc.
712 S.W.2d 349 (Court of Appeals of Kentucky, 1986)
First National Bank v. Curry
301 F.3d 456 (Sixth Circuit, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
James Hamilton Properties, LLC v. Great Midwest Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-hamilton-properties-llc-v-great-midwest-insurance-company-kyed-2022.