Leonard v. First American Property & Casualty Insurance Company

CourtDistrict Court, W.D. Washington
DecidedFebruary 11, 2020
Docket3:19-cv-06089
StatusUnknown

This text of Leonard v. First American Property & Casualty Insurance Company (Leonard v. First American Property & Casualty Insurance Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leonard v. First American Property & Casualty Insurance Company, (W.D. Wash. 2020).

Opinion

1 HONORABLE RONALD B. LEIGHTON 2 3 4 5

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT TACOMA 8 BRANDON LEONARD and ALICIA CASE NO. 3:19-CV-06089-RBL 9 LEONARD, husband and wife and the marital community comprised thereof, ORDER ON MOTION TO REMAND 10 Plaintiff, DKT. # 14 11 v. 12 FIRST AMERICAN PROPERTY & CASUALTY INSURANCE 13 COMPANY; CRAWFORD & COMPANY; and TRIER J. JOHNSON, 14 Defendant. 15

16 THIS MATTER is before the Court on Plaintiffs Brandon and Alicia Leonard’s Motion 17 to Remand. Dkt. # 14. This case is an insurance dispute related to coverage for damages to the 18 Leonards’ home after a fire broke out. Complaint, Dkt. # 1-1, at 2. The Leonards allege that, 19 after their home caught on fire, Defendant First American Property & Casualty Insurance 20 Company unreasonably denied and delayed coverage of their claim, resulting in repeated 21 robberies of their home. Id. at 3-7. In addition to suing First American, the Leonards have also 22 sued First American’s claims adjuster, Crawford & Company, and its employee, Trier Johnson. 23 According to the Leonards, Johnson performed a brief inspection of their home and issued a 24 1 repair estimate that was inaccurate. Id. at 1-1. The Leonards have asserted claims of insurance 2 bad faith, negligent claims handling, negligent misrepresentation, and violation of the 3 Washington Consumer Protection Act against Crawford and Johnson. Id. at 9. Insurance 4 Commissioner records indicate that Johnson maintains a business address in Richland, 5 Washington. Motion to Remand, Dkt. # 14, at 4.

6 First American removed this case to federal court on November 15, 2019. Notice of 7 Removal, Dkt. # 1. In doing so, First American alleged that Defendants Crawford and Johnson 8 were fraudulently joined because the Leonards could not assert claims against First American’s 9 insurance adjusters under Keodalah v. Allstate Ins. Co., 194 Wash. 2d 339 (2019). This would 10 mean complete diversity is satisfied and this Court has subject matter jurisdiction over the case. 11 Id. at 2, 3-4. The Leonards now move to remand on the theory that Keodalah only bars per se 12 CPA claims and statutory bad faith claims against insurance adjusters. Dkt. # 14 at 2. 13 Under the removal statute, “any civil action brought in a State court of which the district 14 courts of the United States have original jurisdiction, may be removed by the defendant . . . to the

15 district court of the United States for the district and division embracing the place where such 16 action is pending.” 28 U.S.C. § 1441(a). Federal subject matter jurisdiction is satisfied if the 17 amount in controversy exceeds $75,000 and all the plaintiffs are completely diverse from all the 18 defendants in terms of state citizenship. 28 U.S.C. § 1332; Caterpillar Inc. v. Lewis, 519 U.S. 61, 19 68 (1996). When analyzing complete diversity, the court may disregard the citizenship of 20 defendants that have been fraudulently joined―i.e., defendants against whom the plaintiff cannot 21 assert a legally-viable claim. Grancare, LLC v. Thrower by & through Mills, 889 F.3d 543, 548 22 (9th Cir. 2018). 23 24 1 On a motion to remand to state court, “[t]he burden of establishing federal jurisdiction is 2 upon the party seeking removal, and the removal statute is strictly construed against removal 3 jurisdiction.” Conrad Assocs. v. Hartford Acc. & Indem. Co., 994 F. Supp. 1196, 1198 (N.D. Cal. 4 1998) (quoting Emrich v. Touche Ross & Co., 846 F.2d 1190, 1195 (9th Cir. 1988)). When the 5 removing party alleges that one of the defendants has been fraudulently joined, remand to state

6 court is required as long as there is a “possibility that a state court would find that the complaint 7 states a cause of action against any of the [non-diverse] defendants.” Grancare, 889 F.3d at 549 8 (Hunter v. Philip Morris USA, 582 F.3d 1039, 1046 (9th Cir. 2009)). This is closer to the 9 “wholly insubstantial and frivolous” standard for dismissing claims under Rule 12(b)(1) for lack 10 of federal question jurisdiction than the plausibility standard of Rule 12(b)(6). Id. (quoting Bell v. 11 Hood, 327 U.S. 678, 682-83 (1946)). 12 Here, the question of whether the Leonards have asserted viable claims against Crawford 13 and Johnson turns on Keodalah v. Allstate Ins. Co., 194 Wash. 2d 339 (2019).1 The trial court in 14 Keodalah dismissed the plaintiff’s claims of insurance bad faith and per se CPA violations

15 against his insurance company’s adjuster. Id. at 343. However, the court of appeals reversed in 16 part, holding that the duty of good faith imposed by RCW 48.01.030 applies to adjusters and 17 could therefore support the plaintiff’s statutory bad faith and per se CPA claims. Id. at 344. But 18 the Supreme Court of Washington reversed again and concluded that RCW 48.01.030, as well as 19 several Washington regulations, only establish a duty of good faith between an insured and their 20 insurer, not an insured and their insurer’s adjuster. Id. at 350-352. 21 22

1 First American also argues that the Court should exercise its discretion to dismiss Crawford and 23 Johnson as dispensable parties under Rules 19 and 21. Dkt. # 15 at 10. The Court declines to do so. 24 1 In reaching its decision, the Court only addressed the statutory duty of good faith and left 2 the plaintiff’s common law duty of good faith claim unaddressed. First American suggests that, 3 because the appellate court did not reverse the trial court’s dismissal of these claims and the 4 Supreme Court left that ruling untouched, the Court implicitly held that such claims are not 5 viable. Opposition, Dkt. # 15, at 8 (citing Keodalah v. Allstate Ins. Co., 413 P.3d 1059 (Wash.

6 Ct. App. 2018). But Justice Yu’s dissent in Keodalah determined that the Court wrongly 7 overlooked the plaintiff’s common law bad faith claim that the court of appeals never reached. 8 194 Wash. 2d at 356 (Yu, J., dissenting). According to Justice Yu, Washington’s framework for 9 imposing a tort duty supports a common law bad faith cause of action against adjusters. Id. at 10 356-63. 11 In addition to overlooking common law bad faith, the majority in Keodalah also 12 emphasized that the plaintiff only asserted a per se CPA violation. Id. at 349. This allowed the 13 Court to hold that the CPA claim should be dismissed solely because no statute created a duty of 14 good faith. Id. at 352. But Panag v. Farmers Ins. Co. of Washington establishes that a plaintiff

15 need not have a contractual or non-adversarial relationship with the defendant to assert a CPA 16 claim. 166 Wash. 2d 27, 41-42 (2009). This would seemingly leave the door open to a traditional 17 CPA claim against an insurance adjuster. 18 In light of this, the Court cannot say that the Leonards’ claims against Crawford and 19 Johnson have no possibility of success. Keodalah’s holding did not reach the type of common 20 law bad faith claim asserted by the Leonards.

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Related

Bell v. Hood
327 U.S. 678 (Supreme Court, 1946)
Caterpillar Inc. v. Lewis
519 U.S. 61 (Supreme Court, 1996)
Emrich v. Touche Ross & Co.
846 F.2d 1190 (Ninth Circuit, 1988)
Murray v. Mossman
355 P.2d 985 (Washington Supreme Court, 1960)
Hunter v. Philip Morris USA
582 F.3d 1039 (Ninth Circuit, 2009)
Tank v. State Farm Fire and Casualty Co.
715 P.2d 1133 (Washington Supreme Court, 1986)
Conrad Associates v. Hartford Accident & Indemnity Co.
994 F. Supp. 1196 (N.D. California, 1998)
William Merriman, et ux v. American Guarantee & Liability Insurance Co.
396 P.3d 351 (Court of Appeals of Washington, 2017)
Moun & Aung Keodalah v. Allstate Insurance Company And Tracey Smith
413 P.3d 1059 (Court of Appeals of Washington, 2018)
Grancare v. Ruth Thrower
889 F.3d 543 (Ninth Circuit, 2018)
Keodalah v. Allstate Ins. Co.
449 P.3d 1040 (Washington Supreme Court, 2019)

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Bluebook (online)
Leonard v. First American Property & Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leonard-v-first-american-property-casualty-insurance-company-wawd-2020.