Jarret McGilloway and Linda Estrella, on Behalf of Themselves and All Others Similarly Situated v. Safety Insurance Company / Adam Ercolini, on Behalf of Himself and All Others Similarly Situated v. the Commerce Insurance Company

CourtMassachusetts Superior Court
DecidedJune 26, 2024
Docket1784CV02089-BLS2 / 1884CV01627-BLS2
StatusPublished

This text of Jarret McGilloway and Linda Estrella, on Behalf of Themselves and All Others Similarly Situated v. Safety Insurance Company / Adam Ercolini, on Behalf of Himself and All Others Similarly Situated v. the Commerce Insurance Company (Jarret McGilloway and Linda Estrella, on Behalf of Themselves and All Others Similarly Situated v. Safety Insurance Company / Adam Ercolini, on Behalf of Himself and All Others Similarly Situated v. the Commerce Insurance Company) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jarret McGilloway and Linda Estrella, on Behalf of Themselves and All Others Similarly Situated v. Safety Insurance Company / Adam Ercolini, on Behalf of Himself and All Others Similarly Situated v. the Commerce Insurance Company, (Mass. Ct. App. 2024).

Opinion

SUPERIOR COURT

JARRET MCGILLOWAY AND LINDA ESTRELLA, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED v. SAFETY INSURANCE COMPANY / ADAM ERCOLINI, ON BEHALF OF HIMSELF AND ALL OTHERS SIMILARLY SITUATED v. THE COMMERCE INSURANCE COMPANY

Docket: 1784CV02089-BLS2 / 1884CV01627-BLS2
Dates: May 31, 2024
Present: Kenneth W. Salinger
County: SUFFOLK
Keywords: DECISION AND ORDER DENYING MOTIONS TO AMEND THE OPERATIVE COMPLAINTS

Jarret McGilloway, Linda Estrella, and Adam Ercolini seek to represent plaintiff classes to press claims that Safety Insurance Company and the Commerce Insurance Company allegedly committed breaches of contract, and engaged in unfair insurance settlement practices, by not paying every potential class member for lost resale value that their motor vehicle allegedly suffered after being damaged in a collision and then fully repaired. The kind of loss that plaintiffs seek to recover is known as “inherent diminished value” or “IDV.” See McGilloway v. Safety Ins. Co., 488 Mass. 610, 611 & n.4 (2021).

Earlier in these proceedings, the Supreme Judicial Court determined that the 2008 standard Massachusetts automobile insurance policy required insurers to pay third-party collision damage claims “for IDV to vehicles that are damaged and subsequently repaired, provided that the claimant establishes both (1) that his or her vehicle suffered IDV, and (2) the amount of IDV damages owed to him or her.” Id. at 611. “In short, if a third-party claimant’s vehicle suffers IDV even after it is fully repaired, then under part 4 of the standard policy, the insurer may be liable to the claimant for IDV damages so that he or she may be ‘made whole’ once again.” Id. at 614–615.

After this SJC decision, the Court denied motions for class certification because it found, based on its evaluation of expert opinions submitted by each side, that liability must be determined separately for every putative class member. Unhappy with that result, Plaintiffs propose a different class definition and

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seek to introduce a new expert opinion; they contend that class certification is appropriate based on this new definition and evidence.

Though the Plaintiffs styled their motions as seeking to leave to amend their complaints for a second or third time, in reality the motions are seeking reconsideration as to class certification. The Court will treat the motions as seeking reconsideration and deny them for two reasons. First, Plaintiffs have not shown there is any reason to revisit the Court’s prior ruling. Second, the conclusory expert opinions that they seek to submit are not supported by any analysis, study, data, or evidence of any kind.

In any case, the Court would deny the motions even if it were to treat them as motions to amend, because the proposed amendments would be futile in light of the defects in the expert opinions that they seek to introduce.

1. Prior Denial of Class Certification. In their current complaints, Plaintiffs sought to represent classes of people who (i) owned vehicles that suffered at least $500 in property damage as a result of a collision with a vehicle that was insured, or whose driver was insured, by Safety Insurance Company or Commerce Insurance Company, and (ii) did not receive any IDV damage payment from Safety or Commerce. They sought to represent the proposed classes with respect to claims for breach of contract under the governing insurance policies and for violating G.L. c. 93A by allegedly engaging in unfair claims settlement practices in violation of G.L. c. 176D.

The Court denied Plaintiffs’ motions for class certification because it found “that individualized inquiry would be required for each member of the proposed classes to determine whether their damaged vehicle suffered any uncompensated IDV loss, and thus to determine whether Safety or Commerce is liable to that class member for breach of contract or for violating G.L. c. 93A and G.L. c. 176D.” The Court also found “that individualized proof, analysis, and findings would be required to determine whether any putative class member’s vehicle suffered some amount of IDV and, if so, how much.”

The Court made these findings after crediting the sworn testimony by Commerce’s valuation expert, Philip Ibrahim, that:

o If a vehicle is involved in a collision, suffers damage, and then is fully repaired, determining whether the vehicle’s resale market value is less than it would have been immediately before the collision

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requires detailed and individualized analysis of many factors, including—

* the nature and severity of the damage and the quality of the repairs;

* whether the vehicle had a prior accident history;

* in what manner the vehicle is to be sold after being repaired (e.g., private sale, retail sale, trade-in);

* the general class of vehicle   (e.g., inexpensive sedans, minivans, high-end luxury vehicles, etc.); and

* the market segment of buyer involved in any subsequent sale.

o Many vehicles that are damaged in a collision and then are fully- repaired do not suffer any IDV, but instead are worth just as much and sometimes even more after being repaired than they were worth before the collision.

o For example, after Adam Ercolini’s 2010 Honda Accord was damaged in a collision and then repaired it was worth at least the same as, if not more than, it was worth immediately before the collision.

In its prior decision, the Court explained that it did “not credit the unexplained opinion of plaintiffs’ expert, Paul Amoruso, that any IDV damages can be determined using nothing but a standard vehicle valuation guide (like the one published by the National Automobile Dealers Association) and the damage appraisal report for each vehicle.” Instead, the Court credited “Mr. Ibrahim’s testimony about the many additional factors that would have to be considered on an individual basis to determine whether any damaged and repaired vehicle suffered IDV and, if so, to what extent.”

The Court also found that, “even if Mr. Amoruso were correct in suggesting that each IDV analysis could be much simpler than Mr. Ibrahim describes, … that would not change the fact that liability cannot be determined on a class- wide basis and instead would have to be decided individually for the tens of thousands or hundreds of thousands of members of each proposed class.”

And the Court made a concluding finding “that the evidence presented in connection with the class certification motions confirms that, as the SJC noted

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earlier in this case, ‘individualized proof is required to demonstrate that a given automobile has sustained some form of diminished value due to a collision or vehicular accident, even after  repairs  are  made.’ ”  McGilloway,  488  Mass.  at 617–618.

Based on those findings, the Court ruled that class certification was not appropriate in either of this civil actions.

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Jarret McGilloway and Linda Estrella, on Behalf of Themselves and All Others Similarly Situated v. Safety Insurance Company / Adam Ercolini, on Behalf of Himself and All Others Similarly Situated v. the Commerce Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jarret-mcgilloway-and-linda-estrella-on-behalf-of-themselves-and-all-masssuperct-2024.