Johnson v. Smith Bros. Ins., LLC

CourtVermont Superior Court
DecidedFebruary 18, 2020
Docket1062-12-18 Cncv
StatusPublished

This text of Johnson v. Smith Bros. Ins., LLC (Johnson v. Smith Bros. Ins., LLC) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johnson v. Smith Bros. Ins., LLC, (Vt. Ct. App. 2020).

Opinion

Johnson v. Smith Bros. Ins., LLC, No. 1062-12-18 Cncv (Toor, J., Feb. 18, 2020).

[The text of this Vermont trial court opinion is unofficial. It has been reformatted from the original. The accuracy of the text and the accompanying data included in the Vermont trial court opinion database is not guaranteed.]

STATE OF VERMONT SUPERIOR COURT CIVIL DIVISION Chittenden Unit Docket No. 1062-12-18 Cncv

Johnson et al. vs. Smith Brothers Insurance, LLC et al.

ENTRY REGARDING MOTION

Count 1, Breach of Contract (1062-12-18 Cncv)

Title: Motion for Summary Judgment (Motion 2) Filer: Smith Brothers Insurance, LLC et al. Attorney: Robin Ober Cooley Filed Date: October 10, 2019

Opposition filed on 12/16/2019 by Attorney Edward D. Fitzpatrick for Plaintiff Joseph M. Finnigan et al Reply filed on 01/10/2020 by Attorney Robin Ober Cooley for Defendant Scott J. Garcia et al.

This case involves claims by a law firm against its (presumably now former)

malpractice insurer and insurance agent. It arises out of a denial of coverage for a scam

by which the lawyers were duped into wiring over $100,000 to someone falsely posing as

opposing counsel in a real estate closing. Defendants move for summary judgment.

Facts

The parties agree that Garcia was an agent of the Smith Brothers Insurance agency,

and that he spoke at a Vermont Attorneys Title Insurance seminar on June 11, 2014.

Plaintiffs allege that Garcia spoke about the importance of proper cybersecurity coverage

for lawyers, and that Attorney Finnigan then spoke with Garcia, “express[ing] an interest

in securing the proper malpractice insurance policy with cyber security coverage,

including email scams resulting in fraudulent wire transactions.” Finnigan Aff. ¶ 7.

Plaintiffs also allege that Garcia said he would need to review their existing policy, but “felt confident that he could provide better coverage” than the firm then had. Id. Finnigan

believed that such coverage would include “the appropriate cyber security coverage that

was discussed at the seminar, including circumstances involving fraudulent wire scams.”

Id. Plaintiffs allege that they sent Garcia a copy of their existing policy with another

company, in response to Garcia’s stating that he would have to review that. Id. ¶¶ 7-8.

Neither side has any written or email record of that policy being exchanged.

The parties agree that a month after the seminar the firm applied online for, and

then purchased, a malpractice policy from Smith Brothers. The online application made

no mention of the month-old conversation with Garcia or anything about cybersecurity

coverage. The parties had no further communications about the specific nature of the

coverage. Finnegan asserts that the firm “assumed that we were getting the cyber security

coverage as represented at the seminar, which was the primary reason for our reaching

out to the Defendants and establishing a relationship with them.” Id. ¶ 9. They renewed

the policy on more than one occasion.

The policy provided $10,000 for “network breach coverage.” The $10,000 limit

was clearly stated in the policy. Policy at 3, § A.6 (Ex. 13 to Motion). There was no coverage

for the event that occurred here. When the firm made a claim for the $100,000 loss, it

was denied for lack of any coverage for such wire scams.

Discussion

The complaint asserts claims for breach of contract, consumer fraud, and negligent

misrepresentation.1 Defendants move for summary judgment on each count.

1 Plaintiffs now seek to amend the complaint to add counts of negligence and breach of the covenant of good faith and fair dealing. The court will address that motion separately. 2 Defendants argue that the conversation at the seminar did not create any contract.

The court agrees. There was no agreement at the seminar to provide insurance. It was a

preliminary informational discussion, nothing more. “To be an enforceable contract, the

agreement must manifest the parties’ intention to be bound and its terms must be

sufficiently definite.” J & K Tile Co. v. Wright & Morrissey, Inc., 2019 VT 78, ¶ 12. A

general discussion about a product is far from sufficient. In addition, although the parties

dispute whether Plaintiffs ever provided a copy of their existing policy for Garcia to

compare, there is no evidence at all that Garcia ever said he had reviewed it and the

cybersecurity coverage he could offer would be better. There was never any offer and

acceptance until the application was submitted a month later making no mention of

cybersecurity coverage, a policy was offered, and Plaintiffs accepted it. Because Plaintiffs

did not request the special coverage, Defendants had no obligation to provide it.

Consumer Protection Claim

Defendants argue that the consumer fraud claim fails because insurance is not

within the scope of the “goods or services” covered by the Vermont Consumer Protection

Act (formerly the Consumer Fraud Act), 9 V.S.A. § 2351a. See Wilder v. Aetna Life & Cas.

Ins. Co., 140 Vt. 16, 18 (1981). Plaintiffs respond that the statute was amended after

Wilder to broaden the scope of such goods or services. The Supreme Court has not yet

addressed whether the amendment included insurance. See Greene v. Stevens Gas

Service, 2004 VT 67, ¶ 10, 122 Vt. 90. Trial courts are apparently split. Judge (now

Justice) Eaton held in 2012 that because the long list of additions such as “objects, wares,

goods, commodities, work, labor, intangibles” did not expressly include insurance, and

there was no mention of Wilder at the time of the amendment, insurance was not included

in the amendment. Nautilus Ins. Co. v. Loomis, Docket No. 194-9-10 Oecv (Feb. 29, 2012).

3 Judge Mello recently reached the same conclusion. See Brunelle v. Cincinnati Ins. Co.,

Docket No. 268-8-16 Frcv (May 24, 2019). The counter-argument, of course, is that the

language on its face is extremely broad, covering “other property or services of any kind.”

9 V.S.A. § 2451a. See Blake v. Progressive Northern Insur., 164-9-15 Oecv (Feb. 4, 2016).

(Tomasi, J.); Bertelson v. Union Mutual Fire Ins., Docket No. 834-04 Cncv (Nov. 22,

2004) (Norton, J.). Lacking any ambiguity, resort to legislative intent is unnecessary.

Flint v. Dep’t of Labor, 2017 VT 89, ¶ 5, 205 Vt. 558 (“[W]e resort to other tools of

statutory construction—such as legislative history—only if the plain language of the

statute is unclear or ambiguous.”).

The court agrees with Plaintiffs here that the statute does cover the sale of

insurance. Insurance coverage is within the description of “intangibles” or “property or

services of any kind.” 9 V.S.A. § 2451a. It is also persuasive, as Judge Norton pointed out,

that in another subsection of the same provision “the sale of insurance” is expressly

excluded from the definition of “home solicitation sales” that are covered by the statute.

Id. § 2451(d)(5). There would be no reason to exclude insurance sales if they were not

covered to begin with.

Nonetheless, the court agrees that the facts proffered here cannot make out a

consumer protection violation. The only representation Plaintiffs point to is Garcia’s

statement “that he could get Plaintiffs better coverage for cyber security than their

existing policy.” Opp. at 14. To establish a violation of the statute, any reliance on such a

statement must be “reasonable under the circumstances.” Jordan v. Nissan N. Amer. Inc.,

2004 VT 27, ¶ 5, 176 Vt. 465.

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Related

Lavallee v. Pratt
166 A.2d 195 (Supreme Court of Vermont, 1960)
Jordan v. Nissan North America, Inc.
2004 VT 27 (Supreme Court of Vermont, 2004)
Wilder v. Aetna Life & Casualty Insurance
433 A.2d 309 (Supreme Court of Vermont, 1981)
Greene v. Stevens Gas Service
2004 VT 67 (Supreme Court of Vermont, 2004)
Paul Flint v. Department of Labor
2017 VT 89 (Supreme Court of Vermont, 2017)
J & K Tile Company
2019 VT 78 (Supreme Court of Vermont, 2019)

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Bluebook (online)
Johnson v. Smith Bros. Ins., LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-smith-bros-ins-llc-vtsuperct-2020.