John N. Parke v. Progressive Casualty Insurance Company

CourtMissouri Court of Appeals
DecidedJune 16, 2020
DocketED108358
StatusPublished

This text of John N. Parke v. Progressive Casualty Insurance Company (John N. Parke v. Progressive Casualty 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
John N. Parke v. Progressive Casualty Insurance Company, (Mo. Ct. App. 2020).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION FOUR

JOHN N. PARKE, ) No. ED108358 ) Appellant, ) Appeal from the Circuit Court ) of St. Louis County v. ) 19SL-CC00661 ) ) PROGRESSIVE CASUALTY ) INSURANCE COMPANY, ) Honorable Stanley J. Wallach ) Respondent. ) FILED: June 16, 2020

OPINION

John N. Parke (“Parke”) appeals from the judgment of the trial court granting summary

judgment in favor of Progressive Casualty Insurance Company (“Progressive”) in Parke’s suit

for fraudulent misrepresentation. On appeal, Parke asserts that there remained genuine issues of

disputed material fact, and also that the trial court erred in finding Parke had no private right of

action under the Registration and Licensing of Motor Vehicles Chapter of the Missouri Revised

Statutes (“the salvage statutes”). We reverse and remand for further proceedings in accordance

with this opinion.

Background

In November 2018, Parke purchased a 2013 Nissan Sentra (“the Sentra”) from Doxa

Auto, LLC (“Doxa”). Parke subsequently noticed damage to the vehicle and obtained an

AutoCheck report, which revealed the Sentra had been reported in an accident in August 2018, and that after the accident, Progressive had purchased the Sentra. The AutoCheck report

indicated, as relevant to the issues raised on appeal, that the Sentra had been reported as an

“insurance loss or probable total loss record” following a “major damage incident,” but that it

had “no salvage or salvage auction record.”

Parke obtained counsel and sent a letter to Progressive, requesting information about the

extent of the damage to the Sentra. Parke informed Progressive that if it had declared the Sentra

a “salvage” vehicle, Progressive was required to apply for a salvage certificate of title. Parke

notified Progressive that if Progressive did not respond to the letter, Parke would assume the

Sentra was a salvage vehicle and that Progressive should have applied for a salvage title.

Progressive did not respond to Parke’s letter.

Parke filed suit against Doxa and Progressive. As to Progressive, Parke alleged

fraudulent misrepresentation. Parke asserted that Progressive had declared the Sentra to be a

salvage vehicle, which it had purchased from the insured as a result of a settlement resulting

from the August 2018 accident, and thus Progressive had breached its duty under Section

301.227, RSMo., 1 to obtain a negotiable salvage certificate of title from the Director of Revenue

(“DOR”). Parke further claimed that as a result of Progressive’s actions, Parke sustained

damage.

Progressive filed a motion to dismiss Parke’s claim of fraudulent misrepresentation

against Progressive, asserting that Parke had not pled a basis upon which Progressive owed him a

duty, in that the statute does not create a private right of action, but rather that Section 301.229

provides for enforcement only by the DOR. Progressive submitted an affidavit from its manager

of claims attesting that Progressive had not declared the Sentra to be a salvage vehicle. Because

1 All statutory references are to RSMo. (cum. supp. 2018), unless otherwise indicated.

2 Progressive’s memorandum in support of its motion to dismiss included matters outside the

pleadings, the trial court converted Progressive’s motion to dismiss into one for summary

judgment pursuant to Rule 55.27(a). Parke responded there was a genuine issue of material fact

whether Progressive had declared the Sentra to be a salvage vehicle before applying for a non-

salvage certificate of title from the DOR.

The trial court granted Progressive’s motion for summary judgment, concluding that

Parke could not maintain an action against Progressive because the salvage statutes created

neither an express nor an implied private right of action; rather, the statute’s language providing

for enforcement by the DOR and criminal punishment was penal and thus contrary to an

individual right of action. After concluding Parke had no private right of action, the trial court

decided it need not reach the issue of whether there existed a dispute of material fact regarding

whether Progressive had declared the Sentra a salvage. The trial court entered judgment against

Parke and in favor of Progressive. This appeal follows.

Standard of Review

Appellate courts review de novo a trial court’s grant of summary judgment. ITT

Commercial Corp. v. Mid-Am. Marine Supply Corp., 854 S.W.2d 371, 376 (Mo. banc 1993).

We will affirm the grant of summary judgment if no genuine issues of material fact exist, and the

movant is entitled to judgment as a matter of law. Id. at 377. We review the record in the light

most favorable to the party against whom judgment was entered. Id. at 376.

Discussion

Parke raises two points on appeal. First, he argues the trial court erred in granting

summary judgment to Progressive because there was a genuine issue as to whether Progressive’s

description of the Sentra in its internal claims file as a “total loss” and a “salvage” constituted a

3 declaration that the Sentra was a “salvage vehicle” as defined by Section 301.010(53), 2 thereby

triggering Progressive’s mandatory obligation to apply for a salvage title under Section

301.227.1. Second, he argues the trial court erred in granting summary judgment to Progressive

after concluding Parke had no private right of action against Progressive under Section

301.227.1. We address the points out of order, for ease of analysis.

Point II

In Parke’s second point on appeal, he argues the trial court erred in granting summary

judgment to Progressive when it held that Parke’s action sought to directly enforce Section

301.227.1, for which there was no private right of action; instead, Parke contends his action was

based on the common law claim of fraudulent misrepresentation, for which the duty element was

triggered by Progressive’s violation of Section 301.227.1. We agree.

Parke here asserted a common law claim against Progressive for fraudulent non-

disclosure, which in Missouri falls under the rubric of fraudulent misrepresentation. Hess v.

Chase Manhattan Bank, USA, N.A., 220 S.W.3d 758, 765 (Mo. banc 2007); Richards v. ABN

AMRO Mortgage Group, Inc., 261 S.W.3d 603, 607 (Mo. App. W.D. 2008). For a claim of

fraudulent non-disclosure, liability arises from a party’s silence “where the law imposes a duty to

speak.” Hess, 220 S.W.3d at 765. Whether or not there exists a duty to disclose is determined

by the facts of each individual case. Id.

Parke asserted as the basis for Progressive’s liability that it remained silent about the

Sentra’s status as a salvage vehicle in the face of its statutory duty to disclose this status imposed

by Section 301.227.1. Section 301.227.1 provides that:

2 We use the statute in effect at the time the petition was filed. See Walsh v. Walsh, 184 S.W.3d 156, 157 (Mo. App. E.D. 2006). When Parke commenced this action, the salvage vehicle definition was found in Section 301.010(53), RSMo. (cum supp. 2018).

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

Related

Walsh v. Walsh
184 S.W.3d 156 (Missouri Court of Appeals, 2006)
Martin v. Martin, Martin & Richards, Inc.
991 S.W.2d 1 (Court of Appeals of Texas, 1997)
Dierkes v. Blue Cross & Blue Shield of Missouri
991 S.W.2d 662 (Supreme Court of Missouri, 1999)
ITT Commercial Finance Corp. v. Mid-America Marine Supply Corp.
854 S.W.2d 371 (Supreme Court of Missouri, 1993)
Richards v. ABN AMRO Mortgage Group, Inc.
261 S.W.3d 603 (Missouri Court of Appeals, 2008)
Hess v. Chase Manhattan Bank, USA, N.A.
220 S.W.3d 758 (Supreme Court of Missouri, 2007)
O'Brien v. B.L.C. Insurance Co.
768 S.W.2d 64 (Supreme Court of Missouri, 1989)
Johnson v. Kraft General Foods, Inc.
885 S.W.2d 334 (Supreme Court of Missouri, 1994)
Baugus v. Director of Revenue
878 S.W.2d 39 (Supreme Court of Missouri, 1994)
Hargis v. JLB Corp.
357 S.W.3d 574 (Supreme Court of Missouri, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
John N. Parke v. Progressive Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-n-parke-v-progressive-casualty-insurance-company-moctapp-2020.