Liberty Surplus Insurance Corporation v. Hamrick & Evans, LLP

CourtDistrict Court, N.D. California
DecidedOctober 4, 2021
Docket3:20-cv-03669
StatusUnknown

This text of Liberty Surplus Insurance Corporation v. Hamrick & Evans, LLP (Liberty Surplus Insurance Corporation v. Hamrick & Evans, LLP) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Liberty Surplus Insurance Corporation v. Hamrick & Evans, LLP, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 LIBERTY SURPLUS INSURANCE Case No. 20-cv-03669-EMC CORPORATION, 8 Plaintiff, ORDER GRANTING PLAINTIFF’S 9 MOTION FOR SUMMARY v. JUDGMENT 10 SETH SAMUELS, et al., Docket No. 49 11 Defendants. 12 13 14 Plaintiff Liberty Surplus Insurance Corporation initiated this insurance coverage action 15 against two groups of defendants: (1) the Hamrick Defendants1 ( “Hamrick”) and (2) the Samuels 16 Defendants2 (“Samuels”). Liberty’s insured is Hamrick. Hamrick consists of a law firm and 17 lawyers who work there. Hamrick was sued for malpractice by its clients, the Samuels. At the 18 trial level, the Samuels prevailed, obtaining a judgment of approximately $4.8 million against 19 Hamrick, but the case is currently on appeal. Liberty filed the instant case, primarily seeking a 20 declaration that (1) under the insurance policy purchased by Hamrick, Liberty has a limit on 21 liability of $2 million and (2) once that $2 million has been exhausted, Liberty has no further 22 obligation to defend or indemnify Hamrick. Apparently, Hamrick assigned any interests it had 23 against Liberty to the Samuels, see Stip., Ex. D (Stip. ¶ B.2), and thus the Samuels stand in 24 Hamrick’s shoes in the instant case. In June 2020, Liberty voluntarily dismissed Hamrick from 25 1 The Hamrick Defendants are: Hamrick & Evans, LLP; Raymond Hamrick III; and Kenneth 26 Greene.

27 2 The Samuels Defendants are: three brothers (Seth Samuels, Stephen Samuels, and Stacy 1 the lawsuit. See Docket No. 18 (notice). 2 Currently pending before the Court is Liberty’s motion for summary judgment. The main 3 || issue before the Court is whether Liberty’s limit on liability is $2 million (for “Each Claim”) or $4 4 || million (in the “Aggregate”), which turns on whether the malpractice claims against Hamrick 5 compose one or two “claims” under the Liberty insurance policy. Liberty claims the former; the 6 || Samuels the latter. Having considered the parties’ briefs and accompanying submissions, as well 7 as the oral argument of counsel, the Court finds Liberty’s position more persuasive and thus 8 GRANTS its motion for summary judgment. 9 I. FACTUAL & PROCEDURAL BACKGROUND 10 The parties stipulated to certain facts and exhibits in conjunction with the motion for 11 summary judgment. The relevant stipulations are as follows. a 12 A. Liberty Policy

13 Hamrick had an insurance policy with Liberty. See Stip. No. 1. A copy of the policy can

14 || be found at Exhibit G (attached to the stipulations).

15 As reflected in Exhibit G, the declarations page states the following limits of liability: $2 Q 16 || million for “Each Claim” and $4 million in the “Aggregate.” Declarations at 2 (bold in original).

= 17 The following comes from the declarations page.

Z 18 19 Lawyers Professional Liability Policy 20 21 TEM 4, LIMITS OF LIABILITY: 9 Each Claim: $ 2,000,000 Aggregate: $ 4,000,000 23 ITEM 5. DEDUCTIBLE: 25 Each Claim: $ 25,000 Aggregate: N/A 26 ITEM 6. PREMIUM: $ REDACTED 28

1 As for the policy itself, § 1 covers the insuring agreement. The policy states in relevant 2 part that the Insured shall be paid “all sums in excess of the Deductible amount and up to the 3 Limits of Liability Stated in the Declarations which the Insured shall become legally obligated to 4 pay as Damages and Claims Expenses as a result of CLAIMS FIRST MADE AGAINST THE 5 INSURED . . . as a result of a Wrongful Act for which the Insured is legally responsible . . . .” 6 Policy at 1 (bold in original). 7 A “Claim” is defined as “a demand received by the Insured for money or services, 8 including the service of suit or institution of arbitration proceedings against the Insured arising 9 out of a Wrongful Act.” Policy at 2 (bold in original). 10 “Damages” is defined as “a monetary judgment or settlement.” Policy at 2 (also stating 11 what damages do not include). 12 “Claim expenses” is defined, inter alia, as “reasonable and necessary fees, costs and 13 expenses charged by any lawyer or any other person or entity retained, selected, or approved by 14 the Company to investigate, defend, and/or settle a Claim.”3 Policy at 2 (bold in original). 15 Section 6 of the insurance policy addresses Limits of Liability. 16 • Section 6(a) addresses the Limits for “Each Claim”: “The liability of the Company 17 for EACH CLAIM . . . shall not exceed the amount stated in the Declarations for 18 Each Claim, and shall include all Claim Expenses.” Policy at 8 (bold in original). 19 • Section 6(b) addresses the Limits for the “Aggregate”: “The total liability of the 20 company for ALL CLAIMS . . . shall not exceed the amount stated in the 21 Declarations as Aggregate, and shall include all Claim Expenses.” Policy at 8 22 (bold in original). 23 Section 6(d) explains that, in certain instances, even if there are multiple claims, those claims are 24 still treated as a single “Claim.” The policy states: “Claims alleging, based upon, arising out of or 25 attributable to the same or related acts, errors or omissions shall be treated as a single Claim 26 . . . .” Policy at 9 (bold in original; italics added). 27 1 After Hamrick was sued for malpractice, it tendered the action to Liberty pursuant to the 2 policy. Liberty agreed to defend under a reservation of rights. See Stip. No. 5. The events 3 underlying the malpractice suit are described below. 4 B. Noriega Project 5 The Samuels were previously a client of Hamrick. In 2002, several years before the 6 Samuels hired Hamrick to provide legal services, the Samuels hired a “general contractor, Pine 7 Wave Construction, Inc. (‘PW1’), for the construction of three adjoining, four-story buildings for 8 mixed use residential (condominiums) and commercial real estate (retail stores and parking) on 9 Noriega Street in San Francisco, California (‘Noriega Project’).” Stip. No. 6. 10 In December 2003, when the construction project was almost finished, “the Samuels 11 discovered there were construction defects in every building system,” including but not limited to 12 windows as well as framing, siding, plumbing, electrical, and so forth. See Stip. No. 7. Defects 13 related to the windows involved “poor window installation [which] left the buildings vulnerable to 14 water intrusion.” Stip No. 8. After PW1 was not able to repair the defects, the Samuels stopped 15 paying, and PW1 abandoned the construction project. See Stip. No. 9. 16 In January 2004, PW1 set up a new company, PW Commercial Construction (“PW2”) and 17 began transferring assets and projects from PW1 to PW2. See Stip. No. 10. 18 C. Arbitration with PW1 19 In May 2004, PW1 filed an arbitration demand against the Samuels. The Samuels 20 responded with a cross-claim, “seeking recovery of the costs to address damage to the interior of 21 the structures caused by water intrusion due to the defective installation of windows, flashing, and 22 related components.” Stip. No. 11. The Samuels were awarded approximately $1.8 million in the 23 arbitration. See Stip. No. 12. 24 Subsequently, “PW1 surrendered its contractor’s license, completed shutdown of its 25 operations, and divested its assets.” Stip. No. 13. 26 D. Representation by Hamrick 27 In December 2006, the Samuels initiated a collection action in state court against PW2 as 1 referred to as the “Collection/Au Action.” See Stip. No. 15. The Samuels initially hired the Rutan 2 & Tucker law firm to represent them in the Collection/Au Action. See Stip. No. 14. 3 In February 2007, PW2 filed for bankruptcy. The bankruptcy proceeding shall hereinafter 4 be referred as the “Bankruptcy Action.” Because of bankruptcy stay, the Collection/Au Action 5 could not proceed as to PW2. See Stip. No. 17.

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Liberty Surplus Insurance Corporation v. Hamrick & Evans, LLP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/liberty-surplus-insurance-corporation-v-hamrick-evans-llp-cand-2021.