Michael Dolan v. Auto Owners Insurance Company

CourtCourt of Appeals of Georgia
DecidedJuly 8, 2015
DocketA15A0384
StatusPublished

This text of Michael Dolan v. Auto Owners Insurance Company (Michael Dolan v. Auto Owners 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
Michael Dolan v. Auto Owners Insurance Company, (Ga. Ct. App. 2015).

Opinion

THIRD DIVISION ELLINGTON, P. J., DILLARD and MCFADDEN, JJ.

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. http://www.gaappeals.us/rules/

July 8, 2015

In the Court of Appeals of Georgia A15A0384. DOLAN et al. v. AUTO OWNERS INSURANCE JE-019 COMPANY.

ELLINGTON, Presiding Judge.

Auto Owners Insurance Company filed this declaratory judgment action

seeking a determination that certain provisions contained in its commercial general

liability policy excluded coverage to its insured, Anthony Hite d/b/a Air Mechanix,

L.L.C. (“Air Mechanix”), for claims arising from Air Mechanix’s alleged negligent

installation of air conditioning ductwork into the home of Michael Dolan and Shana

Jackson. The trial court granted summary judgment to Auto Owners. For the

following reasons, we affirm in part and reverse in part.

To prevail on a motion for summary judgment, the moving party must

demonstrate that there is no genuine issue of material fact, and that the undisputed facts, viewed in a light most favorable to the party opposing the motion, warrant

judgment as a matter of law. OCGA § 9-11-56 (c); Lau’s Corp. v. Haskins, 261 Ga.

491 (405 SE2d 474) (1991).

In brief sum, the pertinent facts are as follows. Dolan and Jackson filed a

complaint against Air Mechanix, among others,1 in the State Court of Chatham

County, asserting claims of negligence per se, professional and simple negligence,

and fraud. The complaint alleged that in March 2009, Air Mechanix replaced the duct

system of the air conditioning unit in their residence. In June 2009, Dolan and

Jackson discovered mold growth on the vent covers. An independent contractor

ultimately concluded that the duct system, which contained holes, gaps, loose

connections, and insufficient mastic, had been defectively installed in violation of the

applicable city ordinances, resulting in excessive moisture and mold contamination

throughout the residence. Dolan and Jackson allege that they grew ill with respiratory

problems as a result and were subsequently forced to vacate the residence and

abandon their personal belongings. Their complaint seeks to recover repair costs,

moving costs, expenses associated with rental property, costs of living, costs related

1 Dolan and Jackson’s complaint against several other defendants was the subject of a separate appeal, Case Number A14A1066, and the trial court’s order in that case was affirmed in an unpublished opinion.

2 to the replacement of personal property, medical expenses, punitive damages,

attorneys fees, and costs of litigation.

Auto Owners, as insurer of Air Mechanix, filed the instant declaratory

judgment action and sought summary judgment that Dolan and Jackson’s claims were

excluded under the terms of its commercial general liability policy. The policy at

issue has a general aggregate policy limit of $2,000,000 (for claims other than

“products-completed operations”), and an additional “products-completed operations”

aggregate limit of $2,000,000.2

Under the general heading of “SECTION I - COVERAGES” and as a subset

of “COVERAGE A. BODILY INJURY AND PROPERTY DAMAGE LIABILITY,”

the policy contains a provision entitled “Exclusions.” Auto Owners contends that

Dolan and Jackson’s property claims are defeated by Exclusions (j) (6) and (j) (7),

which provide:

2. Exclusions

2 A separate provision of the policy allows “one additional Products-Completed Operations Aggregate Limit, for each annual period, equal to the Products-Completed Operations Aggregate Limit” of $2,000,000, provided that “[t]he maximum Products- Completed Operations Aggregate Limit for any annual period will be no more than two times the original Products-Completed Operations Aggregate Limit.”

3 This insurance does not apply to:

...

(j) Damage to Property

“Property Damage”3 to: ...

(6) That particular part of real property on which any insured or any contractors or subcontractors working directly or indirectly on your behalf are performing operations, if the “property damage” arises out of those operations; or

(7) That particular part of any property that must be restored, repaired or replaced because “your work”4 was incorrectly performed on it.

Paragraph (7) of this exclusion does not apply to “property damage” included in the “products-completed operation hazard.”

3 The policy defines “property damage” as “[p]hysical injury to tangible property, including all resulting loss of use of that property” or “[l]oss of use of tangible property that is not physically injured.” 4 The policy defines “your work” as “[w]ork or operations performed by you or on your behalf” and “[m]aterials, parts or equipment furnished in connection with such work or operations.”

4 The policy defines “products-completed operation hazard” as property damage or

bodily injury occurring away from property owned by the Air Mechanix and “arising

out of . . . [Air Mechanix’s] work . . . when all the work to be done at the job site has

been completed.”

Additionally, Auto Owners asserts that Dolan and Jackson’s personal injury

claims are defeated by a separate endorsement pertaining to damage caused by “fungi

or bacteria” (the “Fungi Endorsement”). The Fungi Endorsement excludes coverage

for any “‘bodily injury’ arising out of . . . ‘[a] fungi or bacteria incident,’” and

includes in its definition of “fungi” all “mold, mildew, mycotoxins, spores, scents or

byproducts produced or released by any type or form of fungus.” A “fungi or bacteria

incident” is defined as:

an incident which would not have occurred, in whole or in part, but for the actual, alleged or threatened inhalation of, ingestion of, contact with, exposure to, existence of, or presence of, any “fungi” or bacteria on or within a building or structure, including its contents, regardless of whether any other cause, event, material or product contributed concurrently or in any sequence to such damage.

The endorsement also limits coverage for “property damage” resulting from a “fungi

or bacteria incident” to $50,000.

5 The trial court held that Dolan and Jackson’s claims were defeated in their

entirety by Exclusions (j) (6) and (j) (7), quoted above. The trial court further held

that their bodily injury claims were excluded by the Fungi Endorsement, which it

noted also limited recovery for property damage to $50,000. This appeal follows.

We begin our analysis by noting that

[a]s with any other contract, where the terms of an insurance contract are clear and unambiguous, and capable of only one reasonable interpretation, the court is to look to the contract alone to ascertain the parties’ intent. Even when the trial court is authorized to construe an insurance contract, because a pertinent provision is ambiguous, the trial court must construe strictly against the insurer any ambiguities in the contract and any exclusion from coverage sought to be invoked by the insurer as drafter of the document and must read the insurance contract in accordance with the reasonable expectations of the insured where possible.

(Citations and punctuation omitted.) Henderson v. Georgia Farm Bureau Mut. Ins.

Co., 328 Ga. App. 396, 399 (1) (762 SE2d 106) (2014). Moreover, “[a]n insurer

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Bluebook (online)
Michael Dolan v. Auto Owners Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-dolan-v-auto-owners-insurance-company-gactapp-2015.