Kelly v Liberty Insurance Corp

2018 DNH 106
District Court, D. New Hampshire·Decided May 18, 2018·No. 15-cv-234-JL·Published

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Brendan Kelly

v. Civil No. 15-cv-234-JL Opinion No. 2018 DNH 106 Liberty Insurance Corp., d/b/a Liberty Mutual

ORDER ON SUMMARY JUDGMENT

This insurance coverage case requires the court to

determine whether a named insured validly rejected uninsured

motorist coverage. The dispute arises from a motor vehicle

accident in which plaintiff Brendan Kelly was seriously injured.

Kelly, an employee of Plum Creek Timber Co., was driving a

company truck when an oncoming vehicle crossed a double-yellow

line and collided head-on with Kelly. After collecting the

liability insurance policy limit from the other driver’s

insurance carrier, Kelly sought underinsured motorist (UM)

coverage under an umbrella policy defendant Liberty Mutual

issued to Plum Creek. New Hampshire law requires that umbrella

policies include UM coverage unless rejected by the named

insured. See N.H. Rev. Stat. Ann. § 264:15. Liberty Mutual

denied the claim on the basis that Plum Creek had expressly

rejected UM coverage. Claiming that Plum Creek’s rejection is

invalid under New Hampshire law, Kelly filed a petition for

declaratory judgment seeking coverage under the Liberty Mutual policy. See N.H. Rev. Stat. Ann. 491:22. This court’s subject

matter jurisdiction is premised on diversity of citizenship. 28

U.S.C. § 1332.

The parties filed cross-motions for summary judgment. Two

issues were central to the dispute: 1) whether Liberty Mutual

was required to physically attach a statutorily-required

rejection notice1 to Plum Creek’s policy or notify Plum Creek

employees of the rejection; and 2) whether a particular Plum

Creek employee had the requisite authority to reject UM

coverage. After reviewing the parties’ motions, memoranda and

exhibits and hearing argument, the court denied plaintiff’s

motion and granted defendant’s motion, thereby rejecting

plaintiff’s claim regarding attachment of the rejection notice.2

The court also ruled that material factual disputes remained as

to the Plum Creek employee’s authority, and that issue proceeded

to a bench trial. This order -- issued the same day as the

court’s bench trial rulings -- explains the court’s reasoning as

to its earlier partial grant of summary judgment. The court

1 N.H. Rev. Stat. Ann. § 264:15. 2 See Endorsed Order, March 28, 2017.

2 issues findings of fact and rulings of law from the bench trial

in a separate order.

I. Summary judgment

Summary judgment is properly granted when the movant shows

that there is no genuine dispute as to any material fact and the

movant is entitled to judgment as a matter of law. See Fed. R.

Civ. P. 56(a). The court “views all facts and draws all

reasonable inferences in the light most favorable to the non-

moving” parties. Estrada v. Rhode Island, 594 F.3d 56, 62 (1st

Cir. 2010). On cross-motions for summary judgment, “the court

must consider each motion separately, drawing inferences against

each movant in turn.” Merchants Ins. Co. of N.H., Inc. v. U.S.

Fid. & Guar. Co., 143 F.3d 5, 7 (1st Cir. 1998) (quotation marks

omitted). Here, the parties’ arguments mirror each other. For

example, Kelly claims he is entitled to summary judgment because

New Hampshire law requires an insurer to attach the UM rejection

form to the policy in order to be valid, while Liberty’s summary

judgment motion argues that Plum Creek’s rejection is valid and

conclusive. Thus, while the court treats the motions

separately, it analyzes the arguments in the same intertwined

manner in which they are presented to the court.

3 II. Background

The basic facts are not in dispute. On December 10, 2013,

a car driven by George Motard crossed into Kelly’s lane of

travel and struck the truck Kelly was driving head-on. Motard

was killed in the accident; Kelly was seriously injured. Kelly

claims permanent injury and medical bills to date in excess of

$450,000. At the time of the accident, Kelly was acting in the

course of his employment for Plum Creek, which owned the truck

he was driving. Progressive Casualty Insurance provided

coverage for decedent Motard under a liability policy with a

$100,000 limit. Plum Creek’s primary automobile insurance

carrier was ACE American Insurance Co, with liability and

underinsured motorist coverage limits of $1 million. Both

Progressive and ACE tendered their respective policy limits to

Kelly, who claims that his damages exceed the tendered amount.3

During the relevant time period, Liberty insured Plum Creek

under a commercial umbrella policy with a $5 million limit.

Kelly sought benefits under the Liberty policy, but Liberty

3 Kelly received $100,000 from Progressive and $900,000 from ACE, which permissibly set off the Progressive coverage from its limit. See, e.g., Deyette v. Liberty Mut. Ins. Co., 142 N.H. 560, 563 (1997) (“Recovery by an insured from an underinsured motorist tortfeasor triggers an insurer’s right to reduce payment under underinsured motorist coverage . . . ”).

4 denied the claim, explaining that Plum Creek had expressly

rejected UM coverage under the umbrella policy. This suit

followed.

III. Analysis

The parties agree that New Hampshire law controls this

dispute. Therefore, the insurer, Liberty, bears the burden of

proving that Kelly’s claim is not covered. N.H. Rev. Stat Ann.

§ 491:22-a (2010); Carter v. Concord. Gen. Mut. Ins. Co., 155

N.H. 515, 517 (2011).4

A. Authority to reject UM coverage

New Hampshire law requires that umbrella policies

“provide [UM] coverage equal to the limits of liability purchased, unless the named insured rejects such coverage in writing. Rejection of such coverage by a named insured shall constitute a rejection of coverage by all insureds . . . and shall remain effective upon policy amendment or renewal, unless the named insured requests such coverage in writing.”

4 The parties also disagree as to whether the umbrella policy, as written, provides UM coverage. Because New Hampshire law requires umbrella policies to include UM coverage (unless rejected), this argument is largely academic. Given the statutory mandate of UM coverage and the fact that the statute also allows the named insured to reject such coverage for all insureds, the court declines to resolve this issue, as it will not advance the case of this matter. The outcome turns solely on whether Plum Creek validly rejected the UM coverage mandated by § 264:15.

5 N.H. Rev. Stat. Ann. § 264:15 (emphasis added). The parties

agree that Plum Creek is the “named insured,” and that Kelly is

“an insured” by virtue of the fact that he was operating the

truck in the course of his employment at the time of the

accident.

Liberty argues that Plum Creek rejected UM coverage. It

supports this claim with a copy of a rejection form signed by

Lisa Duetsch, Plum Creek’s Manager of Risk and Insurance.5 In

response, plaintiff argues that the record lacks any evidence

that Duetsch was authorized by Plum Creek to reject the

coverage. As previously noted, on March 28, 2017, the court

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