Kenneth Hughes v. Ace American Insurance Company

CourtCourt of Appeals of Georgia
DecidedMay 26, 2023
DocketA23A0609
StatusPublished

This text of Kenneth Hughes v. Ace American Insurance Company (Kenneth Hughes v. Ace American Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kenneth Hughes v. Ace American Insurance Company, (Ga. Ct. App. 2023).

Opinion

FIFTH DIVISION MCFADDEN, P. J., BROWN and MARKLE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

May 26, 2023

In the Court of Appeals of Georgia A23A0609. HUGHES v. ACE AMERICAN INSURANCE COMPANY.

BROWN, Judge.

Kenneth Hughes appeals from the trial court’s order granting Ace American

Insurance Company’s (“Ace Insurance”) motion for summary judgment. Hughes

asserts that a genuine issue of material fact exists as to whether a passenger van

insured by Ace was owned or operated by a “motor carrier” under OCGA § 40-1-100

et seq. For the reasons explained below, we disagree and affirm.

To prevail at summary judgment, the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the nonmovant’s favor, warrant judgment as a matter of law. We review de novo a trial court’s [grant or] denial of summary judgment, construing the evidence in a light most favorable to the nonmoving party. (Citation and punctuation omitted.) Mornay v. Nat.Union Fire Ins. Co. of Pittsburgh,

PA., 331 Ga. App. 112 (769 SE2d 807) (2015).

So viewed, the record shows that a seven-passenger Dodge Caravan driven by

Jeremiah Belk collided with a Chevrolet Colorado truck driven by Kenneth Hughes

after Belk made an improper lane change. Hughes filed a complaint, as amended,

against Belk’s employer, Normal Life of Georgia, Inc. (“Normal Life”), Res-Care,

Inc. (“Res-Care”), the parent company of Res-Care, and Ace Insurance, the insurance

carrier of Res-Care, asserting various theories of liability for the negligent and/or

reckless conduct of Belk. Hughes asserted a direct action claim against Ace Insurance

pursuant to OCGA § 40-1-112, based on his contention that Normal Life and Res-

Care are motor carriers under OCGA § 40-1-100. The trial court subsequently granted

Ace Insurance’s motion for summary judgment based on its conclusion that there was

no genuine issue of material fact as to whether any of the defendants were a motor

carrier.

Georgia’s direct action provision of the Georgia Motor Carrier Act (“the Act”)

states: “It shall be permissible under this part for any person having a cause of action

arising under this part to join in the same action the motor carrier and the insurance

2 carrier, whether arising in tort or contract.” OCGA § 40-1-112 (c). See generally Sapp

v. Canal Ins. Co., 288 Ga. 681, 682-683 (1) (706 SE2d 644) (2011). “The purpose of

permitting joinder of [an insurance company] in a claim against a [motor] carrier is

to further the policy of the Motor Carrier Act, that is, to protect the public against

injuries caused by the motor carrier’s negligence.” Andrews v. Yellow Freight System,

262 Ga. 476 (421 SE2d 712) (1992). See also Reis v. OOIDA Risk Retention Group,

303 Ga. 659, 664, n.12 (814 SE2d 338) (2018) (Noting that former OCGA § 46-7-12

(c) provided: “‘It shall be permissible under this article for any person having a cause

of action arising under this article to join in the same action the motor carrier and the

insurance carrier, whether arising in tort or contract.’”). Additionally, it “enables

injured persons to recover compensation more efficiently and quickly and encourages

insurers to resolve legitimate claims by settlement.” Grissom v. Gleason, 262 Ga.

374, 378 (3) (418 SE2d 27) (1992). “Importantly, the direct action statute is in

derogation of common law, and its terms require strict compliance.” (Citation and

punctuation omitted.) Stubbs Oil Co. v. Price, 357 Ga. App. 606, 616 (4) (848 SE2d

739) (2020). Cf. Record Truck Line v. Harrison, 220 Ga. 289, 291 (1) (138 SE2d 578)

(1964) (holding different provision of statutory scheme governing motor carriers in

derogation of common law and must be strictly construed).

3 The first step of the analysis is to determine whether Normal Life and Res-Care

fall within the definition of “motor carrier” in the Act. OCGA § 40-1-100 (12) (A)

provides that this term

means: [e]very person owning, controlling, operating, or managing any motor vehicle, including the lessees, receivers, or trustees of such persons or receivers appointed by any court, used in the business of transporting for hire persons, household goods, or property or engaged in the activity of nonconsensual towing pursuant to Code Section 44-1-13 for hire over any public highway in this state.

(Emphasis supplied.) OCGA § 40-1-100 (8) defines “‘for hire’” to mean “an activity

relating to a person engaged in the transportation of goods or passengers for

compensation.” (Emphasis supplied.) And,

“[p]assenger” means a person who travels in a public conveyance by virtue of a contract, either express or implied, with the carrier as to the payment of the fare or that which is accepted as an equivalent therefor. The prepayment of fare is not necessary to establish the relationship of passenger and carrier, although a carrier may demand prepayment of fare if persons enter his or her vehicle by his or her permission with the intention of being carried; in the absence of such a demand, an obligation to pay fare is implied on the part of the passenger, and the reciprocal obligation of carriage of the carrier arises upon the entry of the passenger.

4 OCGA § 40-1-100 (13). Finally, “‘[c]arrier’” is defined to mean “a person who

undertakes the transporting of goods or passengers for compensation.” OCGA § 40-1-

100 (1). Taken together, it is clear from the plain language of the statute that the term

“motor carrier” depends in turn on the definition of “for hire,” which in turn depends

upon the definition of “passenger” found in OCGA § 40-1-100 (13).

Hughes contends that record evidence shows that Normal Life and Res-Care

“operate as a joint enterprise” with both companies “employing” and “directing”

Belk’s activities,1 which included transporting their clients. In his view, a genuine

issue of material fact exists as to “whether the for-profit companies that charged to

provide services including transportation over Georgia roadways” fall within the

definition of motor carrier. He argues that “[t]he law just requires that one purpose

of the vehicle falls within the statutory definition of ‘motor carrier’ — there is no

percentage allocation or analysis of whether the statutorily enumerated services of a

motor carrier are ‘ancillary’ to a business goal.”

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Related

Record Truck Line, Inc. v. Harrison
138 S.E.2d 578 (Supreme Court of Georgia, 1964)
Andrews v. Yellow Freight System, Inc.
421 S.E.2d 712 (Supreme Court of Georgia, 1992)
Grissom v. Gleason
418 S.E.2d 27 (Supreme Court of Georgia, 1992)
Harlan v. Six Flags Over Georgia, Inc.
297 S.E.2d 468 (Supreme Court of Georgia, 1982)
Sapp v. Canal Insurance
706 S.E.2d 644 (Supreme Court of Georgia, 2011)
Haulers Ins. Co. v. Davenport
810 S.E.2d 617 (Court of Appeals of Georgia, 2018)
Reis v. OOIDA Risk Retention Grp., Inc.
814 S.E.2d 338 (Supreme Court of Georgia, 2018)
Mornay v. National Union Fire Insurance
769 S.E.2d 807 (Court of Appeals of Georgia, 2015)
REIS v. OOIDA RISK RETENTIONGROUP, INC.
303 Ga. 659 (Supreme Court of Georgia, 2018)
McIver v. State
875 S.E.2d 810 (Supreme Court of Georgia, 2022)

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Kenneth Hughes v. Ace American Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenneth-hughes-v-ace-american-insurance-company-gactapp-2023.