McCormick v. Allstate Insurance

475 S.E.2d 507, 197 W. Va. 415, 1996 W. Va. LEXIS 126
CourtWest Virginia Supreme Court
DecidedJuly 18, 1996
Docket23261
StatusPublished
Cited by95 cases

This text of 475 S.E.2d 507 (McCormick v. Allstate Insurance) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCormick v. Allstate Insurance, 475 S.E.2d 507, 197 W. Va. 415, 1996 W. Va. LEXIS 126 (W. Va. 1996).

Opinion

ALBRIGHT, Justice:

The appellant in this proceeding, Donald McCormick, is appealing from a final order of the Circuit Court of Kanawha County, West Virginia, in an action which was instituted against his automobile insurer under an automobile policy, Allstate Insurance Company (Allstate). In count one of his complaint, the appellant claimed that Allstate not only failed to honor its insurance contract, but also breached its duty of good faith and fair dealing in handling his claim. As we interpret the claims pleaded and tried, the appellant asserted a cause of action under the principles first enunciated by this Court in Hayseeds, Inc. v. State Farm Fire & Casualty, 177 W.Va. 323, 352 S.E.2d 73 (1986). In a second count, he claimed that Allstate had violated the West Virginia Fan-Trade Practices Act, W.Va.Code § 33-11-4(9), and he sought attorney fees and punitive damages under the principles set out in Jenkins v. J.C. Penney Casualty Insurance Company, 167 W.Va. 597, 280 S.E.2d 252 (1981).

Before the case was actually tried, the circuit court ordered that the trial be bifurcated, with the Hayseeds issues to be tried first and the Jenkins issues to be tried later. The Hayseeds trial resulted in the jury awarding the appellant $995.00 in compensatory damages. Because this amount was substantially less than what the court found the appellant had initially demanded, the court ruled that the appellant had not “substantially prevailed” in his underlying case and that, as a consequence, he was not entitled to pursue his attorney fees and punitive damages. In so doing, the court effectively precluded the appellant from seeking further his Hayseeds and his Jenkins relief.

On appeal, the appellant makes a number of assignments of error which, combined, pose the question of whether the court appropriately precluded the appellant from pursuing his claims for Hayseeds and Jenkins relief after the jury returned its compensatory damages award.

*419 After reviewing the questions raised, this Court cannot conclude that the trial court committed reversible error in denying the appellant attorney fees or in precluding him from seeking punitive damages on the count tried, that is, the Hayseeds count. The Court does believe, however, that the trial court erred in denying the appellant a trial on the Jenkins issue and reverses and remands on that point.

FACTS

The appellant owned a 1984 Ford Escort, which was insured by the appellee, Allstate Insurance Company (Allstate). This vehicle was damaged in a collision on August 28, 1988, and the appellant made a claim under his own insurance policy with Allstate for the damages to the vehicle.

David Dailey, the Allstate adjuster who handled the claim, inspected the vehicle and determined it was a total loss. Allstate calculated the loss payable under the policy to be $1,429.50 and on September 9, 1988, issued its check for that amount, payable to the appellant’s bank which held a lien on the automobile. The payoff on the vehicle loan at that time was $2,808.36.

In determining the amount of the loss, Mr. Dailey consulted the National Automobile Dealer’s Association Used Car Guide (NADA), an approved guide under West Virginia insurance regulations, and determined that the average retail value of the car was $3,100.00. He made the following adjustments to arrive at the $1,429.50 paid the appellant:

[[Image here]]

Although the appellant was unhappy ■with the amount paid by Allstate, there is some dispute as to whether the appellant notified Mr. Dailey of the amount which he felt he was owed and which would reasonably compensate him. We do find that at the trial of this action below, the appellant testified that he never did make a money offer to Allstate or to Mr. Dailey.

On November 4, 1988, appellant filed this action against Allstate and Mr. Dailey. His complaint contained five counts. Two of these counts were strictly against Mr. Dailey, who was later dismissed from the case. Those counts are thus irrelevant to this proceeding. A third count was also eliminated. The two counts which survived, and which are relevant to this appeal, are the Hayseeds count against Allstate and the Jenkins count against Allstate, to which considerable reference has already been made. We note that in pleading the first count, the appellant here alleged a breach of good faith and fair dealing. We note later that bad faith is not an element of the Hayseeds claim. For the surviving counts, the appellant sought $595.00 in damages under the policy terms, $100,000.00 in resulting economic damages, interest, $3,500,000.00 in punitive damages, attorney fees, and costs.

The litigation had a long and rather involved life below, much of which is irrelevant to this proceeding. However, on July 31, 1992, one particularly important event for the resolution of this appeal occurred — the trial court, as has previously been indicated, bifurcated the issues for trial purposes by entering an order which provided:

The trial shall be bifurcated; Phase I to be limited to the Plaintiffs underlying claim and Phase II shall be for the Defendant’s [sic — the Court believes that the trial court mean the plaintiffs (or appellant’s)] implied private cause of action if any, pursuant to the W.Va. Unfair Trade practices Act....

The situation was complicated further by the fact that the parties and the trial court *420 later apparently agreed that, in the trial of the first count, the question of whether the appellant was entitled to compensatory damages and economic loss would first be tried by the jury, and only after the jury returned its verdict on those matters would the remaining damage questions be presented to the jury. 1

A jury trial was conducted commencing on May 2,1994. As tried, the case was restricted to the question of whether Allstate had breached its insurance contract and to what compensatory and economic damages the appellant was entitled, if any.

At the conclusion of the trial, a verdict form was, without objection from either party, submitted to the jury. That form asked the jury to break down the appellant’s damages, if any, into property damages, damages for loss of use of the vehicle, and damages for aggravation and inconvenience. It did not request “net economic damages” or punitive damages, and it did not ask if the appellant “substantially prevailed” on his underlying claim.

At the conclusion of the trial, the jury returned a verdict for the appellant for a total of $995.00. This verdict was composed of $595.00 for Allstate’s underpayment of damages to the appellant’s vehicle and $400.00 for loss of use of the vehicle. No damages were awarded for aggravation and inconvenience.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In re R.B.
West Virginia Supreme Court, 2025
In re R.L. (Separate Included)
West Virginia Supreme Court, 2025
In re Z.D.-1, Z.D.-2, Z.L.-1 and Z.L.-2
West Virginia Supreme Court, 2025
In re K.V.
West Virginia Supreme Court, 2025
In re D.S.
West Virginia Supreme Court, 2025
R.H. v. A.H. and F.H.
West Virginia Supreme Court, 2023
In re M.M.
West Virginia Supreme Court, 2023
Dow v. Liberty Insurance Company
S.D. West Virginia, 2022
Terrence E. v. Christopher R. and Julie R.
West Virginia Supreme Court, 2020
State of West Virginia v. Tracy A. Back
820 S.E.2d 916 (West Virginia Supreme Court, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
475 S.E.2d 507, 197 W. Va. 415, 1996 W. Va. LEXIS 126, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccormick-v-allstate-insurance-wva-1996.