Linda Willis v. Allstate Insurance Company

CourtCourt of Appeals of Georgia
DecidedMarch 27, 2013
DocketA12A2437
StatusPublished

This text of Linda Willis v. Allstate Insurance Company (Linda Willis v. Allstate 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
Linda Willis v. Allstate Insurance Company, (Ga. Ct. App. 2013).

Opinion

FOURTH DIVISION DOYLE, P. J., ANDREWS, P. J., and BOGGS, J.

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. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

March 27, 2013

In the Court of Appeals of Georgia A12A2437. WILLIS v. ALLSTATE INSURANCE COMPANY. A12A2438. ALLSTATE INSURANCE COMPANY v. WILLIS.

ANDREWS, Presiding Judge.

We have consolidated these appeals for disposition because both cases arise

from an action on a homeowners insurance policy issued by Allstate Insurance

Company to Linda Willis. Because Allstate did not act on Willis’s claims on the

policy, Willis sued Allstate. After Allstate did not answer Willis’s complaint and the

case went into default, the trial court granted summary judgment to Allstate on two

of Willis’s allegations and denied Allstate’s motion in limine. These appeals

followed.

In Case No. A12A2437, Willis contends the trial court erred by granting

summary judgment to Allstate on her claims for fraud and promissory estoppel after it had entered a default judgment against Allstate. In Case No. A12A2438, Allstate

contends the trial court erred by holding that Allstate could not introduce evidence

at trial disputing its liability to Willis; by precluding Allstate from offering any

defense at trial, including policy defenses; by denying its request to have only the

well-pled factual allegations of Willis’s complaint read to the jury during the trial of

the case; and by denying Allstate’s motion to exclude the opinion testimony of

Willis’s expert. For the reasons that follow, we affirm the trial court’s rulings in Case

No. A12A2437, and affirm the trial court’s rulings on excluding Willis’s expert, but

we reverse the trial court’s rulings on whether Allstate can introduce evidence on

liability in Case No. A12A2438.

The record shows that while in the process of remodeling her home, Willis

rented a portable storage unit to hold some of her possessions. Because the unit was

placed in her front yard, some of Willis’s neighbors complained, and, without notice

to Willis, the owner of the storage unit removed it from her yard and put it in the

company’s storage yard. Willis reported this to Allstate as a theft. Then, the next day

Willis’s home burned, and Allstate boarded up the house because it determined the

house was unsafe. Willis contends other property of hers was stolen from the boarded

up house. Although Willis filed claims for the stolen property, the fire damage to her

2 home, and the costs of her temporary living expenses, Allstate never paid any of the

claims.

Consequently, Willis filed suit on her policy. After this initial suit was removed

to Federal Court, Willis dismissed the action without prejudice. Sometime later she

filed an identical suit in Fulton County Superior Court, and, although Allstate was

properly served, Allstate failed to answer the complaint, and was in default. Allstate

moved to open the default, which the trial court subsequently denied. Thereafter, the

trial court entered a judgment on liability.

Before the hearing on damages, the trial court made several rulings: It denied

Allstate’s motion to exclude the opinion testimony of Willis’s expert, denied

Allstate’s motion to prevent Willis from arguing to the jury that liability was clear,

and granted Willis’s motion preventing Allstate from contesting liability or offering

any defense to liability. Then, the trial court vacated its earlier order on Allstate’s

motion for partial summary judgment and granted Allstate’s motion on Willis’s

claims for fraud and promissory estoppel. The trial court found that, notwithstanding

the entry of the default, Willis’s claims for fraud and promissory estoppel failed as

a matter of law.

It is well settled in Georgia that

3 [a] judgment by default properly entered against parties sui juris operates as an admission by the defendant of the truth of the definite and certain allegations and the fair inferences and conclusions of fact to be drawn from the allegations of the declaration. Conclusions of law and facts not well pleaded and forced inferences are not admitted by a default judgment.

(Citation and punctuation omitted.) Drug Emporium v. Peaks, 227 Ga. App. 121, 128

(2) (c) (488 SE2d 500) (1997). As we have held,

a defendant in default is in the position of having admitted each and every material allegation of the plaintiff’s petition except as to the amount of damages alleged. The default concludes the defendant’s liability, and estops him from offering any defenses which would defeat the right of recovery.

(Citations and punctuation omitted.) Cohran v. Carlin, 254 Ga. 580, 585 (3) (331

SE2d 523) (1985). Nevertheless,

[i]t is axiomatic that a default does not result in the admission of allegations that are not well-pled or that are the result of forced inferences. The failure to answer or to appear at trial serves as an admission of the facts alleged in the complaint, but not of the conclusions of law contained therein. So while a default operates as an admission of the well-pled factual allegations in a complaint, it does not admit the legal conclusions contained therein. A default simply does not require blind acceptance of a plaintiff’s erroneous conclusions of law.

4 Nor does a default preclude a defendant from showing that under the facts as deemed admitted, no claim existed which would allow the plaintiff to recover.

(Punctuation, footnotes and emphasis omitted.) Grand v. Hope, 274 Ga. App. 626,

629 (1) (617 SE2d 593) (2005).

In relevant part, OCGA § 9-11-55 (a) provides that when a case is in default,

the plaintiff is entitled to judgment “as if every item and paragraph of the complaint

or other original pleading were supported by proper evidence.” The effect of this

provision is well settled in Georgia law. As the Supreme Court of Georgia and this

Court have consistently held, a default operates as an admission of the well-pled facts

alleged in the complaint, but not the conclusions of law contained therein: “A

judgment by default properly entered against parties sui juris operates as an admission

by the defendant of the . . . definite and certain allegations and the fair inferences and

conclusions of fact to be drawn from the allegations of the declaration. Conclusions

of law[] and facts not well pleaded and forced inferences are not admitted by [the]

default judgment.” (Punctuation omitted.) Stroud v. Elias, 247 Ga. 191, 193 (1) (275

SE2d 46) (1981); see also Azarat Marketing Group v. Dept. of Admin. Affairs, 245

5 Ga. App. 256, 257 (1) (b) (537 SE2d 99) (2000); Spears v. Mack & Bernstein, P.C.,

227 Ga. App. 743, 744 (1) (490 SE2d 463) (1997).

Case No. A12A2437

1. Willis’s complaint asserted claims for bad faith, breach of contract, fraud,

negligence, and promissory estoppel. After setting forth the jurisdictional and venue

allegations, the complaint in relevant part alleged the following facts:

Allstate “initially undertook their duty by assigning an adjuster to assess and

handle the claim, and by selecting a contractor of [Allstate’s] choosing to secure and

board up the uninhabitable burned out home of [Willis].” “During this process, a

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