James Maloney and Hadley Maloney v. Benchmark Insurance Company

CourtMissouri Court of Appeals
DecidedApril 27, 2021
DocketWD83411
StatusPublished

This text of James Maloney and Hadley Maloney v. Benchmark Insurance Company (James Maloney and Hadley Maloney v. Benchmark Insurance Company) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Maloney and Hadley Maloney v. Benchmark Insurance Company, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Western District JAMES MALONEY AND HADLEY ) MALONEY, ) ) WD83411 Appellants, ) ) OPINION FILED: April 27, 2021 v. ) ) BENCHMARK INSURANCE ) COMPANY, ) ) Respondent. )

Appeal from the Circuit Court of Cass County, Missouri The Honorable William B. Collins, Judge

Before Division Four: Cynthia L. Martin, Chief Judge, Presiding, Lisa White Hardwick, Judge and Anthony Rex Gabbert, Judge

James Maloney ("Maloney") and his wife, Hadley Maloney (collectively

"Plaintiffs"),1 appeal from a judgment entered in favor of Benchmark Insurance Company

("Benchmark") following a jury trial on Plaintiffs' claim of bad faith failure to settle within

insurance policy limits. Plaintiffs allege that the trial court committed legal error in

1 Because James Maloney and Hadley Maloney share the same surname, we refer to Hadley by her first name for purposes of clarity. No familiarity or disrespect is intended. denying their motion for new trial because Benchmark's counsel engaged in intentional

misconduct by repeatedly violating the trial court's pretrial rulings on motions in limine,

and because Benchmark's counsel suggested an improper adverse inference about a

witness's absence during closing argument. Because the trial court did not abuse its

discretion in denying the motion for new trial, we affirm.

Factual and Procedural Background2

On April 4, 2015, Karla Coronado ("Coronado") negligently drove her vehicle and

caused an accident with a vehicle driven by Maloney. Maloney was injured. At the time

of the wreck, Benchmark insured Coronado and her husband. Benchmark possessed the

power to settle any claims against Coronado. Andres Perez ("Perez") was assigned to

handle Maloney's bodily injury claim against Coronado, and as Benchmark's agent, was

responsible for any investigation necessary to assess liability, coverage, and damages.

Perez determined that Coronado was 100 percent at fault for the accident.

On April 8, 2015, Perez spoke with Maloney by phone and was told that Maloney

went to the emergency room after the accident suffering from neck and shoulder injuries,

and cuts on his hands that required stitches. Maloney reported that he had a CT scan of his

neck and additional X-rays. Perez claimed that Maloney said he would send Perez all of

his medical records, though Perez did not recall sending Maloney a medical authorization

form.

2 "On appeal, in a jury-tried case, we review the evidence and reasonable inferences therefrom in a light most favorable to the jury's verdict, disregarding evidence to the contrary." Rosales v. Benjamin Equestrian Ctr., LLC, 597 S.W.3d 669, 672 n.2 (Mo. App. W.D. 2019) (internal quotation marks omitted).

2 On June 16, 2015, Maloney advised Perez by phone that he would need bilateral

rotator cuff surgery and that his emergency room bill alone was $12,000. Based on this

information, Perez increased the reserves3 on Maloney's claim from $4,200 to $25,000,

Coronado's policy limits. Perez asked Maloney for his medical bills and records. Perez's

supervisor advised that Perez needed to verify Maloney's need for surgery.

Perez sent letters to Maloney on September 3, 2015, and on November 17, 2015,

following up on his request for medical records and bills. The November 17, 2015 letter

provided that if Benchmark did not receive Maloney's medical records and bills within ten

days, his claim would be closed. Maloney acknowledged that he received both of these

letters from Benchmark, and that he did not respond. On November 29, 2015, Perez closed

Maloney's claim due to the lack of response from Maloney.

On January 8, 2016, Maloney sent a demand letter to Perez seeking to settle his

claim for $25,000, Coronado's policy limits, and advised that the demand would expire in

fifteen days. The letter was prepared by Maloney's attorney, though Maloney signed and

sent the letter. The letter stated, "Enclosed is a medical record from the hospital and a

medical record from my doctor's office showing that I had two torn rotator cuffs from this

collision. I need surgery." The letter included nine pages of medical records consisting of

seven pages of an emergency room record and a progress summary note written by a nurse

practitioner from an orthopedic surgeon's office. The nurse practitioner's note summarized

her physical exam of Maloney, and the emergency room records, which included x-rays

3 Perez's supervisor defined reserves as "the value that you place on a claim for the anticipated exposure," or "what you expect to pay on the claim."

3 and MRIs. The summary stated that Maloney required surgery to repair both rotator cuffs,

and that including rehabilitation, the process would require him to take six to nine months

off of work in his job as a custodian. The nurse practitioner's note indicated it was

"pending" as it had not been signed by the treating orthopedic surgeon.

The documents included with Maloney's demand letter did not include the MRI

reports or any of Maloney's medical bills. At the time the demand letter was sent,

Maloney's attorney had medical bills in his possession that exceeded $25,000 in amount.

On January 14, 2016, Perez rejected Maloney's demand. Perez confirmed receipt

of Maloney's demand letter, but advised that he was still in need of Maloney's medical bills.

Perez noted in the claim file, "Requesting policy limits, not represented" and "sent medical

records indicating he needs surgery for his two torn rotator cuffs" and "no bills received,

and yet he is demanding policy limits." Maloney received this correspondence from

Benchmark, but did not send Perez any of his medical bills.

On February 26, 2016, Perez sent another letter requesting all of Maloney's medical

bills and any additional medical records, and stated that once Benchmark received the

documents, it would evaluate Maloney's bodily injury claim. Maloney received this letter

but did not respond. On June 30, 2016, Perez sent Maloney another letter asking for his

medical bills related to the accident.4

On June 20, 2016, Plaintiffs, represented by the same attorney who assisted

Maloney in preparing the January 8, 2016 demand letter, filed suit against Coronado in the

4 At this time, Perez was not aware that Plaintiffs had filed suit against Coronado ten days prior on June 20, 2016.

4 Circuit Court of Cass County ("Underlying Lawsuit"). In August 2016, Benchmark hired

Michael Kirkham ("Kirkham") to defend Coronado's interests in the Underlying Lawsuit.

On December 28, 2017, following a bench trial, a judgment was entered against Coronado

in the Underlying Lawsuit. The judgment assessed Maloney's damages at $430,000 and

Hadley's damages at $10,000, and awarded post-judgment interest at 6.5 percent. On

January 4, 2018, Benchmark issued a payment to Plaintiffs in the amount of $25,000,

Coronado's insurance policy limits, in partial satisfaction of Plaintiffs' judgment against

Coronado.

The Present Suit--Pretrial Rulings

On January 29, 2018, Plaintiffs, represented by new counsel, filed an equitable

garnishment action against Benchmark and Coronado, pursuant to section 379.200,5

seeking recovery from Coronado's insurance policy of unpaid post-judgment interest on

the judgment in the Underlying Lawsuit and costs.

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James Maloney and Hadley Maloney v. Benchmark Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-maloney-and-hadley-maloney-v-benchmark-insurance-company-moctapp-2021.