Lightfoot v. Safeco Insurance Company of America

CourtDistrict Court, W.D. Oklahoma
DecidedMarch 3, 2025
Docket5:24-cv-00604
StatusUnknown

This text of Lightfoot v. Safeco Insurance Company of America (Lightfoot v. Safeco Insurance Company of America) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lightfoot v. Safeco Insurance Company of America, (W.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

RALPH LIGHTFOOT and MYRNA ) LIGHTFOOT, ) ) Plaintiffs, ) ) v. ) Case No. CIV-24-00604-PRW ) SAFECO INSURANCE COMPANY OF ) AMERICA, et al., ) ) Defendants. )

ORDER Before the Court is the Motion to Dismiss (Dkt. 5), filed by Defendants Liberty Mutual Insurance Company and Safeco Insurance Company of America; the Response (Dkt. 6), filed by Plaintiffs Ralph and Myrna Lightfoot; and Liberty Mutual and Safeco’s Reply (Dkt. 7). For the reasons discussed below, the Court GRANTS IN PART and DENIES IN PART the Motion (Dkt. 5). Background This is an insurance contract dispute. The Lightfoots had a homeowner’s insurance policy with Defendant American Economy Insurance Company.1 The Lightfoots allege that a hailstorm damaged their home. They submitted a claim, but according to them, Defendants failed to properly investigate the damage to their home and did not pay the amounts necessary to repair and replace the covered damage to their home. Consequently,

1 Policy No. OY8404019 (Dkt. 5-1). on April 26, 2024, the Lightfoots sued Defendants for breach of contract and breach of the covenant of good faith and fair dealing in the District Court of Oklahoma County. (Dkt. 1- 2). On June 11, 2024, Defendants removed the case to this Court. (Dkt. 1). Liberty Mutual

and Safeco now seek dismissal of the claims against them. Legal Standard In reviewing a Fed. R. Civ. P. 12(b)(6) motion to dismiss, the Court must satisfy itself that the pleaded facts state a claim that is plausible.2 All well-pleaded allegations in the complaint must be accepted as true and viewed “in the light most favorable to the

plaintiff.”3 Additionally, the Court must “draw all reasonable inferences in favor of the non-moving party[.]”4 While factual allegations are taken as true, a court need not accept mere legal conclusions.5 “Labels and conclusions” or “a formulaic recitation of the elements of a cause of action” are not enough to state a claim.6 Additionally, courts may “review documents referred to in the complaint if the documents are central to the plaintiff's

claim and the parties do not dispute the documents’ authenticity.”7

2 Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555–56 (2007). 3 Alvarado v. KOB-TV, L.L.C., 493 F.3d 1210, 1215 (10th Cir. 2007) (citation and internal quotation marks omitted). 4 Doe v. Woodard, 912 F.3d 1278, 1285 (10th Cir. 2019) (citation omitted). 5 Khalik v. United Air Lines, 671 F.3d 1188, 1190–91 (10th Cir. 2012). 6 Id. (internal quotation marks omitted) (quoting Twombly, 550 U.S. at 555). 7 Toone v. Wells Fargo Bank, N.A., 716 F.3d 516, 521 (10th Cir. 2013). Analysis Liberty Mutual and Safeco argue that they should be dismissed because they are not parties to the relevant insurance policy.8 The Lightfoots disagree. But before it can decide

who is right, the Court must determine what law applies. Federal courts sitting in diversity “must apply the substantive law of the state in which it sits, including the forum state’s choice-of-law rules.”9 Here, the forum state is Oklahoma, and its law governs the questions presented by this motion. I. Because Liberty Mutual and Safeco are not parties to the policy, the Lightfoots’ breach of contract claim against them fails. Liberty Mutual and Safeco first argue that the policy at issue only identifies American Economy as the issuer. In Oklahoma, “[i]nsurance policies are ‘contracts interpreted as a matter of law.’”10 To prevail on a breach of contract claim, a party must

prove “(1) formation of a contract; (2) breach of the contract; and (3) damages as a result of that breach.”11

8 Liberty Mutual and Safeco also argue that the Lightfoots did not allege facts sufficient to pierce the corporate veil. The Lightfoots concede that they do not base their allegations on alter ego or veil piercing grounds. Resp. (Dkt. 6), at 1 & n.1, 13. The Court therefore need not address this argument. 9 Boyd Rosene & Assocs., Inc. v. Kansas Mun. Gas Agency, 123 F.3d 1351, 1352–53 (10th Cir. 1997). 10 Curtis v. Progressive N. Ins. Co., No. CIV-17-01076-PRW, 2022 WL 109003, at *5 (W.D. Okla. Jan. 11, 2022) (quoting BP Am., Inc. v. State Auto Property & Cas. Ins. Co., 148 P.3d 832, 835 (Okla. 2005)) (further citation omitted). 11 Morgan v. State Farm Mut. Auto. Ins. Co., 488 P.3d 743, 748 (Okla. 2021). In support, Liberty Mutual and Safeco attached the policy to their Motion. Because the policy is central to the Lightfoots’ claim and they do not dispute its authenticity, the Court may consider the policy itself.12 “[U]nder Oklahoma law, an insured cannot state a

claim for breach of contract against an entity with whom the insured is not in privity of contract.”13 American Economy is the sole issuer identified in the policy. In the “Policy Definitions” section of the policy, “we,” “us,” and “our” is defined as “the underwriting company providing this insurance as shown in [the] Policy Declarations.”14 The underwriting company identified in the “Policy Declarations” section is American

Economy.15 Throughout the policy, the words “we,” “us,” and “our” are used to indicate the contractual promises made by the underwriting company to the insured.16 The policy contains no provisions binding Liberty Mutual or Safeco. In Response, the Lightfoots predominately argue that the facts in their Petition, taken as true, plausibly allege that Liberty Mutual and Safeco are parties to the policy. But

“factual allegations that contradict a properly considered document are not well-pleaded

12 Toone, 716 F.3d at 521. 13 Krohmer Marina, LLC v. Certain Underwriters at Lloyd's, London, 655 F. Supp. 3d 1124, 1130 (E.D. Okla. 2023) (collecting cases). 14 Policy, (Dkt. 5-1), at 22. 15 Id. at 12–14. 16 See, e.g., id. at 25 (listing building property and property losses that “we” cover); Id. at 28 (listing personal property that “we” cover); Id. at 30 (“We do not cover loss caused directly or indirectly by any of the Building Property Losses We Do Not Cover.”) (emphasis omitted); Id. at 34 (“We will pay the amount shown in your Policy Declarations to an eligible person for information leading to the arrest and conviction of the person(s) committing a crime resulting in loss to covered property . . . .”). facts that the court must accept as true.”17 Accordingly, the Court need not defer to Lightfoots’ allegations.18 The Lightfoots next contend that various references to Liberty Mutual and Safeco

throughout the policy somehow bind them to the terms therein. For example, the Lightfoots cite to (1) the policy’s title (“Safeco Premier Homeowners Policy”);19 (2) the logo used throughout the policy (“Safeco Insurance – A Liberty Mutual Company”);20 (3) a letter signed by the president of Safeco, thanking the Lightfoots for renewing the policy;21 (4) references to American Economy as “A Safeco Company”;22 (5) references to

“www.safeco.com” for policy service information, online account services, and information on Safeco’s “website specific privacy and security practices”;23 (6) a disclosure regarding Safeco’s use of the Lightfoot’s personal information;24 and (7) a provision declaring that Safeco “consider[ed] many factors” to determine the Lightfoots’ premium and informing the Lightfoots that they can request that Safeco re-evaluate their policy.25

17 Peterson v.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Alvarado v. KOB-TV, L.L.C.
493 F.3d 1210 (Tenth Circuit, 2007)
Khalik v. United Air Lines
671 F.3d 1188 (Tenth Circuit, 2012)
Peterson v. Martinez
707 F.3d 1197 (Tenth Circuit, 2013)
Toone v. Wells Fargo Bank, N.A.
716 F.3d 516 (Tenth Circuit, 2013)
BP America, Inc. v. State Auto Property & Casualty Insurance Co.
2005 OK 65 (Supreme Court of Oklahoma, 2005)
Wathor v. Mutual Assurance Administrators, Inc.
2004 OK 2 (Supreme Court of Oklahoma, 2004)
Badillo v. Mid Century Insurance Co.
2005 OK 48 (Supreme Court of Oklahoma, 2005)
Doe v. Woodard
912 F.3d 1278 (Tenth Circuit, 2019)
Johnson v. Spencer
950 F.3d 680 (Tenth Circuit, 2020)
MORGAN v. STATE FARM MUTUAL AUTOMOBILE INSUR. CO.
2021 OK 27 (Supreme Court of Oklahoma, 2021)

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Lightfoot v. Safeco Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lightfoot-v-safeco-insurance-company-of-america-okwd-2025.