Miranda v. State Farm General Insurance Company

CourtDistrict Court, D. Nevada
DecidedJune 4, 2025
Docket2:23-cv-01780
StatusUnknown

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

Bluebook
Miranda v. State Farm General Insurance Company, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

3 Gilberto Miranda, et al., Case No.: 2:23-cv-01780-JAD-DJA

4 Plaintiffs Order Denying Cross Motions for Summary Judgment but Dismissing Claims of 5 v. Miranda and Terry

6 State Farm General Insurance Company and State Farm Fire & Casualty Company, [ECF Nos. 24, 25] 7 Defendants 8

9 Future Science Technology Inc. (FST) conducted a medical study to determine the 10 efficacy of an over-the-counter medication on delayed-onset muscle soreness in the days 11 following 60 participants’ short-duration, high-intensity physical exercise. Within 72 hours of 12 the study’s start, however, four of the participants ended up in the hospital with a blood condition 13 called rhabdomyolysis, which causes a breakdown of muscle tissue. Those participants sued 14 FST for their injuries in Nevada state court, and FST tendered the claim to its insurer, State 15 Farm, who denied coverage. That state-court action concluded with a stipulated money 16 judgment and FST’s assignment of its rights against State Farm. 17 Standing in FST’s shoes, the four participants now sue State Farm for breach of the 18 insurance contract, seeking payment of the judgment. They move for partial summary judgment, 19 contending that State Farm’s policy covers the bodily injury they suffered so State Farm’s denial 20 was a breach as a matter of law. State Farm crossmoves for summary judgment. It argues that 21 the participants’ damages do not arise from an accidental occurrence, as required by the policy 22 and, regardless, the loss is expressly excluded by the policy’s professional-services and 23 intentional-acts exclusions. It also moves to dismiss the claims of two of the plaintiffs—Gilberto 1 Miranda and Chad Terry—for their failure to participate in this litigation in violation of a court 2 order compelling discovery. 3 Although I find that this incident is a covered occurrence under the policy, a genuine 4 dispute of material fact exists over whether the intentional-acts exclusion bars coverage for the 5 participants’ losses, so I deny both summary-judgment motions. But because Miranda and Terry

6 have failed to participate in this litigation, prejudicing State Farm’s ability to defend against their 7 allegations, I grant State Farm’s request to dismiss their claims. So this case proceeds to trial on 8 the claims of Bonnie Lo and Chad Moffit only. But first I refer it to the magistrate judge for a 9 mandatory settlement conference. 10 Background

11 Future Sciences Technology Inc., a now-defunct medical-research enterprise, conducted 12 clinical-research studies at Touro University in Henderson, Nevada.1 One of those studies 13 focused on the efficacy of over-the-counter medication on delayed-onset muscle soreness 14 (DOMS).2 The study’s 60 participants were instructed to perform squats to induce DOMS.3 15 Once DOMS symptoms appeared, the researchers gathered data on the efficacy of various 16 treatments.4 Within 72 hours of starting the exercise required by the study, four of the 17 participants, Gilberto Miranda, Bonnie Lo, Chad Terry, and Thomas Moffitt, developed and 18 were hospitalized for rhabdomyolysis, a condition that can cause breakdown of muscles, 19 compartment syndrome, renal failure, or even death.5 20

21 1 ECF No. 28-1 at 4, ¶ 14. 2 Id. at 4, ¶ 12. 22 3 Id. at 4, ¶ 15. 23 4 Id. at 4, ¶ 16. 5 Id. at 4–5, ¶¶ 18, 21, 23. 1 The participants who developed rhabdomyolysis sued FST and its employees in state 2 court, claiming that they were negligent in directing the participants to perform exercises that 3 exceeded their abilities, causing them to incur unexpected medical treatment and costs.6 FST 4 tendered the claim to its insurer, State Farm, which denied the claim,7 taking the position that the 5 conduct giving rise to the suit falls outside the scope of FST’s commercial-general-liability-

6 insurance coverage.8 7 In state court, the participants obtained a stipulated monetary judgment against FST9 and 8 an assignment of FST’s first-party rights against State Farm for the insurance-coverage claim.10 9 Relying on that assignment, the participants sue State Farm for breach of contract, alleging that 10 State Farm had a duty under the insurance policy to defend and indemnify FST, which it 11 breached by “failing to effectuate a prompt, fair, and equitable settlement of the claim; 12 misrepresenting pertinent facts and/or insurance provisions to FST relating to coverage at issue 13 under the terms of the policy; and failing to adopt and implement reasonable standards for the 14 prompt investigation of claims arising under the policy.”11 State Farm removed this coverage

15 case to federal court based on diversity jurisdiction.12 16 The participants now move for summary judgment, contending that “is it clear that” the 17 insurance policy covers the bodily injury they suffered.13 They argue that, as a matter of law, 18

6 ECF No. 26-1 at 6–7, ¶¶ 33, 36. 19 7 ECF No. 28-1 at 3, 5, ¶¶ 11, 27–30. 20 8 Id. at 5, ¶¶ 28, 30. 21 9 ECF No. 28-2. 10 ECF No. 26-1 at 5–6, ¶ 32 (cleaned up). 22 11 ECF No. 28-1 at 7, ¶ 53. 23 12 ECF No 1. 13 ECF No. 24 at 7. 1 insurance coverage must be extended by State Farm because all the requirements for insurance 2 coverage are met. They insist that FST is “legally required to pay damages as a result of the 3 stipulated judgments,” “the [p]laintiffs’ underlying case was based entirely on personal injury,” 4 and “no exclusion applies.”14 5 State Farm crossmoves for summary judgment.15 It contends that, while the plaintiffs’

6 hospitalization was an unexpected result of the study, FST intentionally directed the plaintiffs to 7 engage in exercises with the express goal of developing DOMS, and that intentional act caused 8 their injuries.16 Because the plaintiffs’ injuries do not arise from an accidental occurrence, State 9 Farm argues, they are not covered by the FST policy.17 Even if they were, the loss alleged by the 10 plaintiffs is expressly excluded by the policy terms, State Farm adds.18 It further argues that the 11 participants have put forward no evidence supporting any claim “under Nevada ‘bad faith’ 12 insurance law.”19 State Farm also moves to dismiss all claims by Gilberto Miranda and Chad 13 Terry, two plaintiffs that it says have not participated in this litigation at any point, in violation of 14 a court order.20

15 16 17 18 19 14 Id. at 8. 20 15 ECF No. 25. 21 16 Id. at 8. 17 Id. 22 18 Id. at 15–25. 23 19 Id. at 25. 20 Id. 1 Discussion 2|| A. This case involves only a single claim for breach of contract. 3 Before reaching the merits of the parties’ arguments, I must clear up what appears to be 4! some confusion about the nature of this case. State Farm offers pages of argument about the plaintiffs’ “bad faith” claim and seeks to dismiss it.?7! The participants caption their motion as one for “partial” summary judgment on their breach-of-contract claim.” Then, in their response 7||to State Farm’s arguments, the participants seem to believe that they have “bad faith” claims.” 8|| So before addressing the parties’ summary-judgment arguments, I first clarify the claims that 9|| have actually been pled. 10 The participants have pled just one claim for breach of contract, and no others.” The title 11|| below is the only one for a cause of action, and it is found on page six of the complaint:*° 12 3 4 FIRST CAUSE OF ACTION —- BREACH OF CONTRACT 13 14|| To the extent that the parties believe there is another claim, they have not shown that one exists.

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Miranda v. State Farm General Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miranda-v-state-farm-general-insurance-company-nvd-2025.