Miller v. Trumbull Insurance Company

CourtDistrict Court, D. Arizona
DecidedAugust 13, 2024
Docket2:22-cv-01545
StatusUnknown

This text of Miller v. Trumbull Insurance Company (Miller v. Trumbull Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miller v. Trumbull Insurance Company, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Charles Miller, No. CV-22-01545-PHX-JJT

10 Plaintiff, ORDER

11 v.

12 Trumbull Insurance Company,

13 Defendant. 14 15 At issue is Plaintiff’s Motion for Preliminary Approval of Class Action Settlement 16 and Certification of the Settlement Class (Doc. 51, “Mot.”). After reviewing the Motion, 17 the attached documents, and the relevant case law, the Court will grant the Motion. 18 I. BACKGROUND 19 In 2021, this Court ruled that Arizona law requires stacking of uninsured motorist 20 (“UM”) or underinsured motorist (“UIM”) coverages within a multi-vehicle policy under 21 A.R.S. § 20-259.01(H), where the insurer did not provide the insured an opportunity to 22 elect which vehicle’s coverage was applicable to the claim. Heaton v. Metro. Grp. Prop. 23 & Cas. Ins. Co., No. CV-21-00442-PHX-SRB, 2021 WL 6805629, at *8 (D. Ariz. October 24 19, 2021). In the wake of that ruling, several plaintiffs filed similar cases, alleging the same 25 theory of liability. 26 The first such case before the Court was Franklin v. CSAA General Insurance Co., 27 No. CV-22-00540-PHX-JJT. While Franklin was pending, Plaintiff filed this case in state 28 court, alleging that he was injured in an automotive collision that resulted in over $170,000 1 in damages, and the non-party at fault was uninsured. Plaintiff was insured under a policy 2 with Defendant Trumbull Insurance Company that insured four vehicles at $50,000 per 3 person and an aggregate limit of $10,000 per collision. Plaintiff alleged that Trumbull 4 would not allow him to stack the four vehicles’ coverages despite not complying with 5 A.R.S. § 20-259.01(H). He also sought to certify two classes of similarly situated 6 individuals. Trumbull removed the case to federal court. 7 Meanwhile, in Franklin, the Court certified two questions to the Arizona Supreme 8 Court: “(1) Does A.R.S. § 20-259.01 mandate that a single policy insuring multiple 9 vehicles provides different underinsured motorist (UIM) coverages for each vehicle, or a 10 single UIM coverage that applies to multiple vehicles?” and “(2) Does A.R.S. 11 § 20-259.01(B) bar an insured from receiving UIM coverage from the policy in an amount 12 greater than the bodily injury liability limits of the policy?” Franklin, 2022 WL 16631090, 13 at *2–3. The Arizona Supreme Court answered: 14 (1) § 20-259.01’s text, history, and purpose provide that an insured covered 15 by a multi-vehicle policy has necessarily “purchased” multiple UIM 16 coverages for each vehicle under subsection (H); thus, rather than employing singular definitions of “coverage” in their policies, insurers must comply 17 with the statute’s requirements in order to prevent insureds from intra-policy 18 stacking; and (2) § 20-259.01(B) does not limit UIM coverage. 19 20 Franklin v. CSAA Gen. Ins. Co., 532 P.3d 1145, 1153 (Ariz. 2023). 21 After the Arizona Supreme Court’s answers to the certified questions, Plaintiff and 22 Trumbull engaged in pre-certification settlement negotiations, including a mediation. The 23 parties agreed to negotiate and settle all claims related to UM/UIM coverage for policies 24 sold in Arizona by Trumbull, Hartford Insurance Company of the Southeast, Twin City 25 Fire Insurance Company, Hartford Underwriters Insurance Company, Hartford Insurance 26 Company of the Midwest, and Hartford Casualty Insurance Company (collectively, 27 “Defendants”)1, which are all affiliated companies under common management. After two

28 1 Plaintiff has since filed an Amended Complaint adding each of these companies as a Defendant. (Doc. 44.) 1 mediations and several more months of negotiations, the parties agreed on key terms and 2 entered into a final settlement agreement, agreeing to settle the case for $13,940,000.00. 3 (Doc. 51-1, “Agreement”) 4 Plaintiff now moves for certification of the settlement class and preliminary 5 approval of the settlement agreement. 6 II. LEGAL STANDARD 7 A. Class Certification 8 Federal Rule of Civil Procedure 23(a) provides that a class action—that is, an action 9 in which one or more members of a class sue on behalf of all members of the class—may 10 proceed only if four prerequisites are met: 11 1. Numerosity: “the class is so numerous that joinder of all members is 12 impracticable”; 13 2. Commonality: “there are questions of law or fact common to the class”; 14

15 3. Typicality: “the claims or defenses of the representative parties are typical of the claims or defenses of the class;” and 16

17 4. Adequacy of Representation: “the representative parties will fairly and adequately protect the interests of the class.” 18 19 Fed. R. Civ. P. 23(a). 20 In addition, under Rule 23(b), a court may only certify a class action if there is at 21 least one of the following: 22 1. Risk of Inconsistency: the prosecution of separate actions by individual 23 class members would create a risk of inconsistent adjudications or 24 adjudications that would be dispositive of non-party class member interests; or 25

26 2. Appropriate Class-Wide Injunctive Relief: injunctive or declaratory relief is appropriate respecting the class as a whole because the conduct of the 27 opposing party applies generally to the class; or 28 1 3. Predominance and Superiority: “the court finds that the questions of law or fact common to class members predominate over any questions 2 affecting only individual members, and that a class action is superior to 3 other available methods for fairly and efficiently adjudicating the controversy.” 4 5 Fed. R. Civ. P. 23(b). 6 “Rule 23 does not set forth a mere pleading standard. A party seeking class 7 certification must affirmatively demonstrate his compliance with the Rule—that is, he must 8 be prepared to prove that there are in fact sufficiently numerous parties, common questions 9 of law or fact, etc.” Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 350 (2011). Thus, 10 “‘sometimes it may be necessary for the court to probe behind the pleadings before coming 11 to rest on the certification question.’” Id. (quoting Gen. Tel. Co. of the Sw. v. Falcon, 457 12 U.S. 147, 160 (1982)). Class certification “is proper only if ‘the trial court is satisfied, after 13 a rigorous analysis, that the prerequisites of Rule 23(a) have been satisfied,’” which will 14 frequently “entail some overlap with the merits of the plaintiff’s underlying claim.” Id. at 15 350–51 (quoting Falcon, 457 U.S. at 161). 16 B. Preliminary Approval 17 Class actions require the approval of the district court before settlement. Fed. R. 18 Civ. P. 23(e) (“The claims, issues, or defenses of a certified class—or a class proposed to 19 be certified for purposes of settlement—may be settled, voluntarily dismissed, or 20 compromised only with the court’s approval.”). The Ninth Circuit has declared a strong 21 judicial policy that favors settlement of class actions. Class Plaintiffs v. City of Seattle, 955 22 F.2d 1268, 1276 (9th Cir. 1992); In re Hyundai & Kia Fuel Econ. Litig., 926 F.3d 539, 556 23 (9th Cir. 2019). 24 Procedurally, this process moves forward in two steps. The first step is preliminary 25 approval.

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Miller v. Trumbull Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miller-v-trumbull-insurance-company-azd-2024.