Karen v. United Services Automobile Association

CourtDistrict Court, D. Nevada
DecidedJuly 22, 2025
Docket2:24-cv-02089
StatusUnknown

This text of Karen v. United Services Automobile Association (Karen v. United Services Automobile Association) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Karen v. United Services Automobile Association, (D. Nev. 2025).

Opinion

1 2 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 3 4 Allison Karen, et al., Case No. 2:24-cv-02089-CDS-DJA

5 Plaintiffs Order Granting Defendants’ Motions to Dismiss 6 v.

7 United Services Automobile Association, et al., [ECF Nos. 17, 24] 8 Defendants

9 10 Plaintiffs Allison and Gudrun Karen bring this action against defendants United States 11 Automobile Association (USAA), USAA Casualty Insurance Company (USAA Casualty), 12 Garrison Property and Casualty Insurance Company, and Auto Injury Solutions, Inc./CCC1 13 (collectively, defendants) and allege the following causes of action: (1) declaratory relief, (2) 14 breach of contract, (3) exploitation of the elderly, (4) violation of Nevada’s prohibition on unfair 15 claims practices, and (5) bad faith. Compl., ECF No. 1. USAA, USAA Casualty, and Garrison 16 filed a partial motion to dismiss. First mot. to dismiss, ECF No. 17. That motion is fully briefed. 17 See Opp’n, ECF No. 20; Reply, ECF No. 23. AIS/CCC filed a separate motion to dismiss. Second 18 mot. to dismiss, ECF No. 24. That motion is also fully briefed. See Opp’n, ECF No. 27; Reply, 19 ECF No. 32. For the following reasons, I grant USAA, USAA Casualty, and Garrison’s partial 20 motion to dismiss and I grant AIS/CCC’s motion to dismiss for lack of personal jurisdiction. 21

22 23 24 25 1 Auto Injury Solutions is now known as CCC Intelligent Solutions, Inc., as a result of a merger between 26 the two companies. ECF No. 24 at 1 n.1. For purposes of this motion, CCC states it will respond on behalf of Auto Injury Solutions and that “should this matter survive dismissal, a substitute of entities will be filed.” Id. The court will refer to this party as “AIS/CCC.” 1 I. Background2 2 Plaintiffs allege that they were involved in two motor vehicle accidents that were both 3 caused by the “negligence of an under-insured motorist”: the first on April 29, 2023, and the 4 second on January 12, 2024. ECF No. 1 at ¶¶ 10, 11. At the time of the accidents, the plaintiffs 5 were insured with USAA with uninsured motor policy limits of “$1,000,000.00 per person 6 $1,000,000.00 per accident.” Id. at ¶ 16. Plaintiffs were also insured with USAA for a “stackable 7 medical payment policy limit of $100,000.00 per person per vehicle.” Id. at ¶ 17. The combined 8 policy limits for the underinsured motorist policies identified for both the plaintiffs’ accidents 9 total $2,000,000 and the medical payment policies identified a total for both accidents of 10 $800,000. Id. at ¶ 20. Despite their insurance policies and their demand for settlement, the 11 plaintiffs allege that the defendants “delayed making an offer to settle” and “delayed making 12 payments to the plaintiffs to cover the incurred medical expenses.” Id. at ¶¶ 22, 23. 13 II. Legal standard 14 The Federal Rules of Civil Procedure require a plaintiff to plead “a short and plain 15 statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). 16 Dismissal is appropriate under Rule 12(b)(6) when a pleader fails to state a claim upon which 17 relief can be granted. Fed. R. Civ. P. 12(b)(6); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). A 18 pleading must give fair notice of a legally cognizable claim and the grounds on which it rests, 19 and although a court must take all factual allegations as true, legal conclusions couched as 20 factual allegations are insufficient. Twombly, 550 U.S. at 555. Accordingly, Rule 12(b)(6) requires 21 “more than labels and conclusions, and a formulaic recitation of the elements of a cause of action 22 will not do.” Id. To survive a motion to dismiss, “a complaint must contain sufficient factual 23 matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 24 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility 25 2 As the complaint provides no facts section, the court does its best to parse through the filing to 26 summarize the factual allegations. Citation to the complaint is to provide background and does not serve as a finding of facts. 1 when the plaintiff pleads factual content that allows the court to draw the reasonable inference 2 that the defendant is liable for the misconduct alleged.” Id. This standard “asks for more than a 3 sheer possibility that a defendant has acted unlawfully.” Id. 4 If the court grants a motion to dismiss for failure to state a claim, leave to amend should 5 be granted unless it is clear that the deficiencies of the complaint cannot be cured by 6 amendment. DeSoto v. Yellow Freight Sys., Inc., 957 F.2d 655, 658 (9th Cir. 1992). Under Rule 15(a), a 7 court should “freely” give leave to amend “when justice so requires,” and in the absence of a 8 reason such as “undue delay, bad faith or dilatory motive of the part of the movant, repeated 9 failure to cure deficiencies by amendment previously allowed, undue prejudice to the opposing 10 party by virtue of allowance of the amendment, futility of the amendment, etc.” Foman v. Davis, 11 371 U.S. 178 (1962). 12 III. Discussion 13 A. USAA, USAA Casualty, and Garrison’s partial motion to dismiss is granted. 14 USAA, USAA Casualty, and Garrison filed a motion to dismiss the following claims: (1) 15 declaratory relief, (3) exploitation of the elderly, (4) violation of Nevada’s Unfair Claims 16 Practices Act, and (5) bad faith. ECF No. 17 at 2. I address each claim in turn. 17 USAA, USAA Casualty, and Garrison first argue that the plaintiffs fail to properly plead 18 a claim for declaratory relief under the Declaratory Judgment Act because the plaintiffs did not 19 demonstrate why this relief would be proper under relevant case law. Id. at 4–5. The Declaratory 20 Judgment Act states, “[i]n a case of actual controversy within its jurisdiction . . . any court of the 21 United States . . . may declare the rights and other legal relations of any interested party seeking 22 such declaration.” 28 U.S.C. § 2201(a). The Ninth Circuit has outlined a two-part test to 23 determine whether the court may exercise its jurisdiction under the Declaratory Judgment Act. 24 Principal Life Ins. Co. v. Robinson, 394 F.3d 665, 669 (9th Cir. 2005). First, the court must inquire 25 whether there is an “actual case or controversy within its jurisdiction.” Id. Second, the court 26 must decide whether to exercise its jurisdiction by analyzing the Brillhart factors: (1) avoidance 1 of needless determination of state law issues, (2) discouragement of the use of declaratory 2 judgments to forum shop, and (3) avoidance of duplicative litigation. Chamberlain v. Allstate Ins. 3 Co., 931 F.2d 1361, 1367 (9th Cir. 1991) (citing Brillhart v. Excess Ins. Co., 316 U.S. 491, 495 (1942)). A 4 district court’s exercise of jurisdiction over declaratory relief actions is discretionary.

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Karen v. United Services Automobile Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/karen-v-united-services-automobile-association-nvd-2025.