Lloyd's Syndicate No. 5820 v. Agco Corporation

CourtCourt of Appeals of Georgia
DecidedNovember 30, 2012
DocketA12A1125
StatusPublished

This text of Lloyd's Syndicate No. 5820 v. Agco Corporation (Lloyd's Syndicate No. 5820 v. Agco Corporation) 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
Lloyd's Syndicate No. 5820 v. Agco Corporation, (Ga. Ct. App. 2012).

Opinion

FIRST DIVISION ELLINGTON, C. J., PHIPPS, P. J., and DILLARD, 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/

November 30, 2012

In the Court of Appeals of Georgia A12A1125, A12A1126. LLOYD’S SYNDICATE NO. 5820 d/b/a CASSIDY DAVIS v. AGCO CORPORATION; and vice versa. A12A1281. GLYNN GENERAL PURCHASING GROUP, INC. et al. v. AGCO CORPORATION.

PHIPPS, Presiding Judge.

AGCO Corporation manufactured and sold agricultural equipment, offering

extended protection plans to its customers. Warranty Specialists, Inc. d/b/a Glynn

General Corporation sold the extended protection plans to AGCO and administered

the plans. Glynn General Purchasing Group, Inc. (“GGPG”) obtained a master policy

of liability insurance for AGCO from Lloyd’s Syndicate No. 5820 d/b/a Cassidy

Davis to provide coverage to AGCO for its liability to AGCO’s customers pursuant

to the extended protection plans. When Warranty Specialists later suspended payment

of warranty claims filed in connection with failed wheel motors on equipment enrolled in the extended protection plans, AGCO sued. The trial court granted

AGCO’s motion for partial summary judgment and denied Cassidy Davis’s motion

for summary judgment on the issue of whether the extended protection plans and the

master insurance policy covered or excluded coverage for equipment failures

resulting from a design or engineering defect. The court denied Cassidy Davis’s

motion for summary judgment on AGCO’s claims for bad faith refusal to pay. It also

denied AGCO’s summary judgment motion based on estoppel and the inapplicability

of an exclusion clause in the master insurance policy, and denied summary judgment

to Warranty Specialists and GGPG on various claims, including those for breach of

contract, fraud and attorney fees. For the reasons that follow, we affirm the

judgments.

AGCO manufactured and sold an agricultural spray applicator known as the

RoGator. The RoGator was powered by four wheel motors; the failure of one wheel

motor caused the entire machine to stop functioning.

Beginning in 2005, AGCO offered extended protection plans (“EPPs”) to its

customers who purchased RoGators. AGCO purchased the EPPs from Warranty

Specialists, paying the latter premiums for each RoGator enrolled in an EPP.

Warranty Specialists administered the EPP. Under the EPP, AGCO agreed to repair

2 or replace covered parts of the RoGator, “if required due to a MECHANICAL

BREAKDOWN or FAILURE that is the result of a true defect in material or

workmanship.”

The EPP pertinently provided: “This service contract coverage is limited

exclusively to the repair or replacement of covered parts . . . determined to have failed

due to a MECHANICAL BREAKDOWN or FAILURE as defined under terms and

definitions.” The EPP defined a covered “mechanical breakdown or failure” as “the

actual breaking or electronic failure of any covered part of the covered MACHINE

while in ordinary use arising from faults attributable to manufacturing defects in

workmanship or materials in such MACHINE causing sudden stoppage of the

functions thereof and necessitating repair before it can resume work.”

GGPG obtained a master policy of liability insurance for AGCO from Cassidy

Davis, which provided coverage to AGCO for any liability AGCO had to its

customers for machines enrolled in the EPP.

Pursuant to the EPP and the master policy, the purchaser of a machine that had

a mechanical breakdown or failure presented the machine to one of AGCO’s dealers,

who made the initial determination of coverage; if the repair was covered, the dealer

repaired the machine. The dealer then submitted a claim for reimbursement for the

3 repair cost to Warranty Specialists, who would evaluate and pay or deny claims under

the EPP. Warranty Specialists paid premiums to Cassidy Davis, and Cassidy Davis

paid Warranty Specialists for claims deemed valid.

In mid- to late 2008, after having accepted and paid approximately 25 wheel

motor claims, Warranty Specialists stopped processing the claims. In September

2008, it informed AGCO that it was placing all wheel motor claims on hold until it

received support from AGCO (such as assistance in paying the claims or higher

premiums).

Also in September 2008, Warranty Specialists sent an email message to AGCO

stating that no further wheel motor claims would be paid because, pursuant to the

master policy, Cassidy Davis had invoked the Epidemic Failure Clause in relation to

RoGator wheel motors. “With immediate effect, no further claims should be paid in

respect of any [AGCO] attachments . . .; for the avoidance of doubt this includes any

4 claims pending or subsequently advised.” 1 When Warranty Specialists failed to pay

the dealers’ wheel motor claims, AGCO paid the claims.

AGCO sued Warranty Specialists, Cassidy Davis, and GGPG, seeking

declaratory relief regarding coverage under the master policy and reimbursement for

payment of the warranty claims; asserting claims for breach of contract and bad faith

against Cassidy Davis; asserting claims for breach of contract and fraud against

Warranty Specialists and GGPG; and asserting claims for money had and received

against Warranty Specialists, Cassidy Davis, and GGPG. Cassidy Davis appeals in

Case No. A12A1125; AGCO appeals in Case No. A12A1126; and Warranty

1 The Epidemic Failure Clause [“EFC”] purportedly contained in the master policy provided: In the event that the total number of claims from a common cause for a particular component or components, . . . amounts to more than 10% of the earned units, this shall be considered an “Epidemic Failure”, and will be the sole responsibility of [AGCO]. Accordingly, [AGCO] will be liable for all claims arising from an Epidemic Failure and all claims relating to, or arising from, a component which, by virtue of this clause, is the subject, or cause, of an Epidemic Failure.

5 Specialists and GGPG appeal in Case No. A12A1281. This court reviews the grant

or denial of summary judgment de novo.2

Case No. A12A1125

1. Cassidy Davis contends that the trial court erred by granting AGCO’s motion

for partial summary judgment and by denying its motion for summary judgment on

the issue of whether there was coverage for breakdowns attributable to design defects.

According to Cassidy Davis, the EPP and master policy did not afford coverage for

failures resulting from a design or engineering defect, and the RoGator’s wheel motor

failures resulted from such a defect.3

The trial court ruled that the language of the EPP and master policy was

unambiguous and “[did] not exclude or limit coverage for a design or engineering

defect”; and that, as used in these contracts, the “the term ‘manufacturing defects’

[did] not exclude coverage for breakdowns or failures attributable to, or caused by,

a design defect.” The court granted AGCO’s motion for partial summary judgment

“on the issue of whether the EPP and the master policy provide coverage for a

2 ChoicePoint Srvcs. v. Hiers, 284 Ga. App. 640 (644 SE2d 456) (2007). 3 AGCO does not concede that the failures resulted from a design or engineering defect; it contends that the issue is not determinative because design or engineering defects were covered and not excluded.

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Lloyd's Syndicate No. 5820 v. Agco Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lloyds-syndicate-no-5820-v-agco-corporation-gactapp-2012.