Michael's Fabrics, LLC v. Donegal Mutual Insurance Company

CourtDistrict Court, D. Maryland
DecidedAugust 16, 2024
Docket1:24-cv-01585
StatusUnknown

This text of Michael's Fabrics, LLC v. Donegal Mutual Insurance Company (Michael's Fabrics, LLC v. Donegal Mutual Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael's Fabrics, LLC v. Donegal Mutual Insurance Company, (D. Md. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

MICHAEL’S FABRICS, LLC,

Plaintiff,

Civil Action No. 24-cv-1585-JRR v.

DONEGAL MUTUAL INSURANCE CO., Defendant

MEMORANDUM OPINION AND ORDER Plaintiff Michael’s Fabrics, LLC, which does business as A Fabric Place, see, e.g., ECF No. 14-2 at 2, suffered a flood on January 21, 2023, which Plaintiff alleges caused substantial damage to certain of Plaintiff’s fabric inventory. See, e.g., Compl., ECF No. 1, ¶ 8. The allegedly damaged fabrics were obtained from three suppliers, Gammatex Co. Ltd. (“Gammatex”), Berenstein Textiles (“Berenstein”), and Tip Top Super Fine Fabrics (“Tip Top”). Plaintiff held a property insurance policy through Donegal Mutual Insurance Company (“Donegal”). Compl. ¶ 3 & ECF No. 1-3 (policy). Plaintiff asserted a claim to Donegal, seeking coverage of Plaintiff’s alleged losses of $433,135 worth of fabrics. Donegal denied the claim on two grounds. ECF No. 1-14 (January 19, 2024 denial letter); see also Compl. ¶ 41. First, Donegal contended that Plaintiff had violated the “Concealment, Misrepresentation or Fraud” provision of the insurance policy. ECF No. 1-14 at 2.1 Specifically, Donegal contends that two of the invoices supporting Plaintiff’s claim, both from supplier Tip Top, “were back-dated to dates just prior to the water loss, and listed a large volume of expensive fabric that had not been previously ordered by the plaintiff.” ECF No. 14 at 1-2. See also ECF No. 1-14 at 5 (denial

1 Page numbers refer to the number appearing in the CM/ECF header for this and the other filings referenced herein. letter, stating this basis for denial as that Donegal’s “investigation supports that documentation was altered post loss to align the presentation of the claim with our questions about the invoices”). Second, Donegal took the position that, regardless, it was entitled to deny the claim because Plaintiff had “failed to produce documents requested by Donegal in conjunction with its

investigation of the claim,” an alleged failure that Donegal contends also constituted an independent “breach of the insurance contract.” ECF No. 1-14 at 2. Plaintiff initially filed a complaint with the Maryland Insurance Administration (“MIA”), challenging Donegal’s denial. The MIA dismissed that complaint, because the dispute involved a commercial insurance policy “where the policy limits exceed $1,000,000.” ECF No. 1-15 (citing Md. Code Ann., Cts & Jud. Proc. § 3-1701). Plaintiff then filed this case in June 2024, alleging that Donegal’s denial of the claim breached the insurance policy (count 1), and that Donegal’s handling of the claim, including Donegal’s “demand[s] that Plaintiff produce documents wholly unrelated to the claims of Plaintiff,” constituted bad faith in violation of Md. Code Ann., Ins. § 27-1001 (count 2).

As to Donegal’s denial based on alleged “[c]oncealment, [m]isrepresentation or [f]raud,” the dispute arises principally from correspondence between Plaintiff and supplier Tip Top, as noted above. Following Plaintiff’s filing of the complaint in this case, and in an apparent effort to further investigate Plaintiff’s correspondence with its suppliers in connection with Plaintiff’s insurance claim, Donegal issued subpoenas to Google and Verizon. The subpoenas requested from Verizon “a complete copy of any and all records of all calls and texts from the cell phone of Lee Jonathon Miller,” the owner of Michael’s, “from January 01, 2023 to the present to and from his cell phone,” and from Google “copies of all e-mails sent or received from or to [Lee Miller’s email address] from January 1, 2023 to the present.” ECF No. 13-3 at 5 (Verizon subpoena); 13- 6 at 5 (Google subpoena). In other words, as drafted, the subpoenas sought all of Mr. Miller’s emails, phone calls and text messages—regardless of topic or sender/recipient—for the requested time period. Google and Verizon have informed Donegal that they will only produce documents

pursuant to the subpoenas if (a) ordered by the Court or (b) Mr. Miller expressly authorizes Google and Verizon to produce the requested records. ECF Nos. 14 at 6; 14-16. Mr. Miller declined to authorize production. Instead, Plaintiff filed a motion for a protective order or to quash, arguing that the subpoenas are overbroad and not proportional to the needs of the case. Mot., ECF No. 13 at 11-14. That motion was referred to me pursuant to 28 U.S.C. § 636 and Local Rules 301 and 302. See ECF No. 16. I held a hearing on the motion on August 9, 2024. ECF No. 19. All discovery must be “relevant to any party’s claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). The proportionality requirement in Rule 26 “requires courts to consider, among other things, ‘whether the burden or expense of the proposed

discovery outweighs its likely benefit.’” Virginia Dep’t of Corr. v. Jordan, 921 F.3d 180, 188-89 (4th Cir. 2019) (quoting Fed. R. Civ. P. 26(b)(1)). “When discovery is sought from nonparties,” as is the case here, “its scope must be limited even more,” because the nonparties “are ‘strangers’ to the litigation.” Id. at 189. Federal Rule of Civil Procedure 45 provides “[a] more demanding variant of the proportionality analysis” in this context, id., “to avoid imposing undue burden or expense on a person subject to the subpoena.” Fed. R. Civ. P. 45(d)(1). In determining whether a subpoena must be modified or quashed to avoid undue burden, courts weigh various factors, including “the requesting party’s need for” the information, whether the information “offer[s] some value over and above what the requesting party already has,” “what information is available to the requesting party from other sources,” the financial cost to the nonparty, whether the subpoena “impose[s] a burden by invading privacy or confidentiality interests,” and whether the subpoena is overbroad. Jordan, 921 F.3d at 189-90. As part of this analysis, “the requesting party should be able to explain why it cannot obtain the

same information, or comparable information that would also satisfy its needs, from one of the parties to the litigation.” Id. at 189. The subpoenas Donegal issued to Verizon and Google are unquestionably overbroad. They are not reasonably temporally limited; although some period in 2023 would entail a reasonable scope, Donegal has not adequately explained why it needs records from January 2023 to the present—i.e. a year and a half after the alleged loss—for damages that occurred on January 21, 2023. They are also not reasonably limited in scope. The subpoenas seek all emails, call records and text messages from that period and are not limited to communications between Plaintiff and the three suppliers at issue, Gammatex, Berenstein and Tip Top. See In re Subpoena Duces Tecum to AOL, LLC, 550 F. Supp. 2d 606, 612 (E.D. Va. 2008) (quashing an overbroad

subpoena that was not reasonably limited in scope); Bierman Fam. Farm, LLC v. United Farm Fam. Ins. Co., No. CV ADC-17-0004, 2017 WL 3311206, at *3 (D. Md. Aug. 2, 2017) (same).

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In Re Subpoena Duces Tecum to AOL, LLC
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Michael's Fabrics, LLC v. Donegal Mutual Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michaels-fabrics-llc-v-donegal-mutual-insurance-company-mdd-2024.