Lanigan v. T.H.E. Insurance

28 Pa. D. & C.5th 479
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedMarch 28, 2013
DocketNo. 11250 of 2010, C.A
StatusPublished

This text of 28 Pa. D. & C.5th 479 (Lanigan v. T.H.E. Insurance) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lanigan v. T.H.E. Insurance, 28 Pa. D. & C.5th 479 (Pa. Super. Ct. 2013).

Opinion

PICCIONE, J.,

Before the court for disposition are competing motions for summary judgment filed on behalf of the plaintiff, William Michael Lanigan (hereinafter, “plaintiff’), and the defendant, T.H.E. Insurance Company (hereinafter, “defendant”). The current action arises from an insurance claim submitted by plaintiff to defendant following a motor vehicle accident involving the plaintiff at the Mercer Raceway Park on March 31,2007.

Plaintiff was driving a race car at the Mercer Raceway Park on March 31, 2007. While plaintiff was participating in a race on that date, the throttle of his race car stuck causing plaintiff’s car to strike the catch fence along the race track. Samuel Ketcham and Steven W. Guthrie, Jr. were standing on the opposite side of the catch fense when plaintiff lost control of his race car. Mr. Ketcham suffered serious injuries and Mr. Guthrie died as a result of the accident.

Mr. Ketcham and the estate of Steven W. Guthrie, Jr. filed personal injury lawsuits against plaintiff and Mercer Raceway Park. Plaintiff contacted defendant and requested defendant provide plaintiff with insurance liability coverage, including a defense against the estate of Steven Guthrie, Jr., and Mr. Ketcham under insurance policies that defendant issued to Mercer Raceway Park. Defendant declined coverage for plaintiff. On August 18, 2010, plaintiff initiated the present action against defendant, asserting breach of contract and bad faith claims in his complaint. Defendant subsequently filed an answer and [481]*481new matter, followed by a reply and new matter from plaintiff. Defendant filed a motion for judgment on the pleadings on March 31, 2011, which was denied by order of court and opinion dated July 8, 2011. A subsequent motion for judgment on the pleadings filed by plaintiff was also denied by order of court dated August 11, 2011.

Defendant filed a motion for summaiy judgment on November 26, 2012. On January 22, 2013, Plaintiff also filed a motion for summary judgment. The two motions for summary judgment were consolidated for argument on February 25, 2013, and are presently before the court for a determination.

Under Pennsylvania law, the standard for summary judgment is set forth by Rule 1035.2 of the Pennsylvania Rules of Civil Procedure. The Rule states:

After the relevant pleadings are closed, but within such time as not to unreasonably delay trial, any party may move for summary judgment in whole or in part as a matter of law
(1) whenever there is no genuine issue of any material fact as to a necessary element of the cause of action or defense which could be established by additional discovery or expert report, or
(2) if, after the completion of discovery relevant to the motion, including the production of expert reports, an adverse party who will bear the burden of proof at trial has failed to produce evidence of facts essential to the cause of action or defense which in a jury trial would require the issues to be submitted to a jury.

[482]*482Pa.R.C.P. 1035.2. The moving party bears the burden of proving that no genuine issue of material fact exists. Rush v. Philadelphia Newspapers, Inc., 732 A.2d 648, 650 (Pa. Super. 1999). In determining whether summary judgment is appropriate, the trial court is required to view the record in a light most favorable to the non-moving party, and “all doubts as to the existence of a genuine issue of material fact must be resolved in favor of the nonmoving party.” P.J.S. v. Pennsylvania State Ethics Comm’n, 732 A.2d 174 (Pa. 1999) (citing Kapres v. Heller, 640 A.2d 888 (Pa. 1994)). Summary j udgment is proper only when the uncontroverted allegations of record and submitted affidavits demonstrate that no genuine issue of material fact exists, and that the moving party is entitled to judgment as a matter of law. Potter v. Herman, 762 A.2d 1116, 1117 (Pa. Super. 2000).

The crux of the issue presently before the court is based on whether Mr. Guthrie and Mr. Ketcham were “participants” at the time of the accident. The parties do not dispute that plaintiff was a participant in the race on March 31,2007. Plaintiff argues that defendant had a duty to defend plaintiff in the personal injuiy actions initiated by Mr. Ketcham and the estate of Steven W. Guthrie, Jr. based upon the facts asserted in their respective complaints against plaintiff. Defendant alternatively asserts that it had sufficient information at the time the complaints were initiated to establish that plaintiff, Mr. Guthrie and Mr. Ketcham were all “participants” in the race when the accident occurred. Defendant contends that, as a result, plaintiff is not owed coverage under the language of the policies issued to Mercer Raceway Park for this reason.

An insurer’s duty to defend is broader than its duty to [483]*483indemnify. Kvaerner Metals Div. of Kvaerner U.S., Inc. v. Commercial Union Ins. Co., 908 A.2d 888 (Pa. 2006); General Acc. Inc. Co. of America v. Allen, 692 A.2d 1089, 1095 (Pa. 1997). It is a distinct obligation, separate and apart from the insurer’s duty to provide coverage. Erie Ins. Exch. v. Transamerica Ins. Co., 533 A.2d 1363 (Pa. 1987). An insurer is obligated to defend its insured if the factual allegations of the complaint on its face encompass an injury that is actually or potentially within the scope of the policy. Id. at 1368 (describing the duty to defend as arising “whenever the complaint filed by the injured party may potentially come within the coverage of the policy.” (emphasis in original)); Gedeon v. State Farm Mut. Auto. Ins. Co., 188 A.2d 320 (Pa. 1963); Cadwallader v. New Amsterdam Cas. Co., 152 A.2d 484, 488 (Pa. 1959) (“It is clear that where a claim potentially may become one which is within the scope of the policy, the insurance company’s refusal to defend at the outset of the controversy is a decision it makes at its own peril.”). As long as the complaint “might or might not” fall within the policy’s coverage, the insurance company is obliged to defend. Casper v. Am. Guar. & Liab. Ins. Co., 184 A.2d 247, 249 (Pa. 1962) (quoting Judge Learned Hand’s assertion in Lee v. Aetna Casualty & Surety Company, 178 F.2d 750, 752 (2d Cir. 1949)). Accordingly, it is the potential, rather than the certainty, of a claim falling within the insurance policy that triggers the insurer’s duty to defend.

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Bluebook (online)
28 Pa. D. & C.5th 479, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lanigan-v-the-insurance-pactcompllawren-2013.