Jumptastics, LLC v. Auto-Owners Insurance Company

CourtDistrict Court, E.D. Kentucky
DecidedSeptember 29, 2023
Docket6:21-cv-00172
StatusUnknown

This text of Jumptastics, LLC v. Auto-Owners Insurance Company (Jumptastics, LLC v. Auto-Owners 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
Jumptastics, LLC v. Auto-Owners Insurance Company, (E.D. Ky. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY SOUTHERN DIVISION (at London)

JUMPTASTICS, LLC, et al., ) ) Plaintiffs, ) Civil Action No. 6:21-CV-172-CHB-HAI ) v. ) ) MEMORANDUM OPINION AUTO-OWNERS INSURANCE ) AND ORDER COMPANY, et al., ) ) Defendants. )

*** *** *** *** This flood insurance dispute is before the Court on the motions for summary judgment filed by Defendants Lakeland Group, Inc., d/b/a Lakeland Insurance Group, and Krista Slade Russell, [R. 38], and Defendant Auto-Owners Insurance Co., [R. 39]. The motions have been fully briefed by the Defendants and by Plaintiffs Jumptastics, LLC, and Danielle Davis. See [R. 40]; [R. 41]; [R. 42]; [R. 43]. For the following reasons, Lakeland and Russell’s Motion [R. 38] will be GRANTED in part and DENIED in part, and Auto-Owners’ Motion [R. 39] will be GRANTED. I. Background

The facts in this case are relatively simple, even if the legal framework surrounding flood insurance claims is quite technical. Davis formed Jumptastics, an entertainment venue with inflatables, in 2017. See [R. 38-2 (Articles of Incorporation)]; [R. 38-4, p. 29 (Davis deposition)].1 In 2020, Jumptastics sought to purchase the property in Somerset, Kentucky, that it had leased

1 The record contains excerpts of several individuals’ depositions. See, e.g., [R. 38-4]; [R. 39-4]. Some of the deposition transcripts contain four pages of testimony per document page; for these exhibits, the Court will cite to the deposition page number, and line number, as necessary. since 2017. See [R. 38-3 (“Flood Insurance Policy Packet”)]; [R. 38-4, pp. 14:20–21]. Davis’s bank required a flood insurance policy for the building before it would close on the loan.2 See [R. 38-4, pp. 16–18]. Davis went to Lakeland to source the policy; she and her husband had used Lakeland to source many policies in the past and had often used Russell as their agent. See id. at 41:25–42:24, 95–96 (Davis: “I think we started doing business with Lakeland like in 2013, I want

to say, and we purchased policies for Davis Communications. . . . [T]hen we also have purchased Jumptastics, home, vehicle; pretty much every policy that we have, on every business.”). Russell was a licensed insurance agent with Lakeland, and she assisted Davis in obtaining coverage for the property. See id. at 49; see also [R. 38-1, p. 2]. Because Davis did not know all of the requirements for the type of policy that she needed, Davis instructed Russell to work with her bank to determine the type of coverage needed for the property, and Russell was “the one that did the application process.” See [R. 38-4, pp. 18:21–25, 49:11–19, 57:7–58:7] (Davis: “[Krista] asked me what flood coverage I needed. I told her I was not for sure exactly. I just thought flood coverage was flood coverage, and she said she had never written a flood policy before, but that I

could put her in contact with Josh and she would find out what the bank was requiring . . . .”). Throughout this process, Russell submitted documents on Davis’s behalf, including elevation building determinations. See [R. 40-4 (excerpts from Russell’s deposition and elevation certificates)]. Ultimately, Jumptastics obtained a policy through Auto-Owners, underwritten by Torrent Corporation. See [R. 38-3 (“Flood Insurance Policy Packet”)]. Auto-Owners issued Jumptastics a standard flood insurance policy (“SFIP”), pursuant to the National Flood Insurance Program

2 The loan on the property was actually in the name of Davis Communications, a company Davis owned with her husband. See [R. 38-4, pp. 11:6, 15:21–22]. Jumptastics then leased the property from Davis Communications. See id. at 21:7–8. (“NFIP”). See id.; [R. 39-2, p. 2 ¶ 3 (Brandeberry affidavit)]. Such policies “promise indemnification for damage caused by flood or rising waters.” Neuser v. Hocker, 246 F.3d 508, 509 (6th Cir. 2001). The policy term was for July 1, 2020, to July 1, 2021, and provided limits of $165,000.00 for building damages and $25,000.00 for contents damages, each subject to a $5,000.00 deductible. See [R. 39-2, p. 3 ¶ 9].

On February 28, 2021, Somerset had a major flood, and approximately eleven inches of water came into Jumptastics’ building. See [R. 38-4, pp. 27:24–25, 29:25] (Davis: “I was told it was a hundred-year flood that happened here in this area.”). On March 1, 2021, the Plaintiffs reported a claim under their policy for damages to the property resulting from the flooding. See [R. 39-2, p. 4 ¶ 10]. Auto-Owners appointed an independent adjuster to inspect the property and adjust the claim as afforded under the policy’s provisions. See id. (citing Article VII(J)(7)(8)). The adjuster recommended, and Auto-Owners verified, that “the total amount of SFIP covered and payable flood damage totaled $19,143.57.” Id. This finding was based on the determination that the policy had originally been incorrectly rated for being on a slab, rather than a basement. See id.

at ¶ 11. Relevant here, during the claims process, the independent adjuster discovered that the property did not fit the information provided in Jumptastics’ application; as a result, Auto-Owners hired an engineer to provide the proper building description and rating information for Auto- Owners to determine the rating and coverage for the property. Id. “Keystone Engineering discovered and confirmed that the floor surface of the lower level of Plaintiffs’ property was below exterior grade on all sides of the building, and therefore, the Plaintiffs’ building has a basement” rather than a slab. See id. (citing Article II(B)(5)). Importantly, policy “coverage of certain specific items of property in a basement is limited.” Id. (citing Article III(A)(8) and (B)(3)). Therefore, Auto-Owners applied the basement coverage limitations to the areas of Jumptastics’ building that met the policy definition of “basement,” and the “Plaintiffs’ claim to recover for flood damaged building and contents items that exceeded the limited coverage were denied on June 7, 2021.” Id. at ¶ 12. Notably, despite extensive communications among all parties, the Plaintiffs never timely

filed a proof of loss as required by the policy. See id. at 4–5 ¶¶ 10, 13 (“[D]espite repeated requests to Plaintiffs, including but not limited to a correspondence issued on April 8, 14, & 28, 2022, and June 3 & 7, 2022, that Plaintiffs return executed proofs of loss required by their SFIP, Plaintiffs never complied. Therefore, Plaintiffs’ claim was closed without payment.”). Instead, Davis refused to sign the proof of loss offered by Auto-Owners for $19,143.57 that was based on the “basement” determination. See id. at 5 ¶ 13; [R. 38-4, pp. 35–39]. She does claim, however, to have signed and submitted on May 28, 2021, the initial report of the adjuster without the basement limitation. See [R. 40-8 (Davis affidavit)]. Davis’s affidavit to this effect failed to attach the initial report of the adjuster.

On September 29, 2021, Davis and Jumptastics filed suit against Auto-Owners, Lakeland, and Russell in Pulaski Circuit Court. See [R. 1-1]. The Complaint contains four causes of action: breach of contract against Auto-Owners (Claim I); failure to procure insurance against Lakeland and Russell (Claim II); failure to advise against Lakeland and Russell (Claim III); and violation of the Kentucky Unfair Claims Settlement Practices Act, KRS § 304.12-230 against all Defendants (Claim IV). See id. at 4-7. The Plaintiffs seek certain types of damages as relief. See id. at p. 7 ¶¶ 1–8. On October 6, 2021, Auto-Owners removed the action to this Court based primarily on the exclusive federal jurisdiction over claims that challenge the disposition of claims under a SFIP. See [R.

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Jumptastics, LLC v. Auto-Owners Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jumptastics-llc-v-auto-owners-insurance-company-kyed-2023.