Mountainside v. Vt Mutual Ins

Vermont Superior Court·Decided September 5, 2024·No. 22-cv-4513·Published

Opinion

Vermont Superior Court

Filed 12/01 23

Washington mt

SUPERIOR COURT £2 £4 CIVIL DIVISION Washington Unit f‘i Case No. 22—CV—04513 65 State Street

Montpelier VT 05602 802-828-2091 £5 WWW.Vermontjudiciary.org

Mountainside Condominium Association V. Vermont Mutual Insurance

Opinion and Order on Cross-Motions for Summarv Judgment In this insurance case, the parties dispute the insured’s right to pre-award interest for benefits that a panel of arbitrators determined it was entitled to receive. Mountainside Condominium Association (“Mountainside”) argues that it is entitled to the interest because its claim for benefits was reasonably ascertainable and not seriously in dispute. Vermont Mutual Insurance Company (“Vermont Mutual”) disagrees and argues that Mountainside waived its right to pre-award interest by releasing Vermont Mutual from “any and all extra-contractual Claims.” Vermont Mutual also contests the merits of Mountainside’s request for interest. Both parties have filed motions for summary judgment.

The Court has considered the submissions of the parties, as well as the contentions made at oral argument. It makes the following determinations.

Undisputed Facts

The parties do not dispute the following facts. In February 2014, a fire completely destroyed Mountainside’s Building 3 in its Warren, Vermont complex. Vermont Mutual provided an insurance policy to Mountainside that covered the property loss (“Policy”). Vermont Mutual made advance coverage payments to

Mountainside from 2014 through 2020 based on Vermont Mutual’s “undisputed loss measure.” Mountainside was placed in a receivership from June 2018 through June 2022. The replacement of Building 3 was completed by September 30, 2020.

Vermont Mutual started requesting records associated with the reconstruction of Building 3 starting in 2017. Mountainside never provided Vermont Mutual with a sworn proof of loss. After failed attempts to negotiate a final resolution of Mountainside’s claim for first-party benefits, Mountainside demanded arbitration.

On January 16, 2020, Mountainside and Vermont Mutual entered into an agreement (“the Agreement”) that included the following language:

1) Receiver/MCA releases VM from any and all extra-contractual claims associated with its adjustment of claims for benefits arising from the February 2014 fire at Building 3.

2) Within two (2) business days of the full execution of this agreement by all necessary parties, an advance of $1,500,000 of the recoverable depreciation based on VM’s undisputed loss measure will be wired into MCA’s escrow account . . . .

....

4) Receiver/MCA waives its right to file suit against VM. This waiver does not include a suit for a breach of this Agreement.

5) Any remaining dispute between Receiver/MCA concerning entitlement to first-party benefits under the policy for reconstruction of

Building shall be submitted to binding arbitration with a panel of three (3) arbitrators.

The parties agreed that their arbitration would be conducted pursuant to the Federal Arbitration Act (“FAA”). When Mountainside’s claim was submitted to arbitration, its claim for total construction costs was $11,493,058.30. Of this amount, Vermont Mutual paid $8,415,336 in benefits under the Policy to Mountainside before the arbitration took place.

Procedure Before Arbitration Panel Prior to submitting their dispute to arbitration in November 2022, the parties disagreed about whether the arbitrators were authorized to award Mountainside pre-award interest and vigorously briefed this issue to the panel. See Exhibits 7, 8, and 11 to Mountainside’s Statement of Facts. Vermont Mutual asserted that Mountainside waived its right to pre-award interest when it agreed to release Vermont Mutual from “any and all extra-contractual claims associated with its adjustment of claims for benefits.” See Agreement, ¶ 1. Mountainside disputed that pre-award interest was included within the meaning of “extra-contractual claims,” as that term was used in the Agreement, and took the position that the arbitrators were authorized to make an award for pre-award interest. According to Vermont Mutual, the arbitrators did not have the authority to arbitrate arbitrability, meaning that they lacked the authority to determine the issues that were subject to arbitration.

The arbitration panel issued its decision on November 4, 2022, stating, in its entirety:

Vermont Mutual Insurance Company shall pay Mountainside Condominium Association $2,031,366.

As there was not clear and unmistakable evidence that it was the intent of the parties to give the Panel the authority to arbitrate arbitrability, the Panel lacks the authority to rule on Mountainside Condominium Association’s claim for interest.

The Panel makes no ruling on interest.

Arbitrators are not required to provide an explanation or reasoning for their decision “beyond the award figure.” Vermont Built, Inc. v. Krolick, 2008 VT 131, ¶ 14, 185 Vt. 139, 147 (citing Shahi v. Ascend Fin. Servs., Inc., 2006 VT 29, ¶ 13, 179 Vt. 434, 440). Vermont Mutual paid the $2,031,366 award to Mountainside on November 16, 2022, twelve days after the award was made.

Post-Arbitration Procedure After the arbitrators issued their decision, Mountainside initiated this case by filing an application for a confirmation of the arbitrators’ award pursuant to 9 U.S.C. § 9, which is part of the FAA, and for an award of prejudgment interest.1

1 According to the statute, “[i]f no court is specified in the agreement of the parties

[for a judgment to be entered upon the arbitration award], then such application may be made to the United States court in and for the district within which such award was made.” 9 U.S.C. § 9. The Agreement does not specify a court to enter judgment following the arbitration. State courts have concurrent jurisdiction with federal

That section requires a court to issue an order confirming the award “unless the award is vacated, modified, or corrected as prescribed in sections 10 and 11 of this title.” 9 U.S.C. § 9; see Shamah v. Schweiger, 21 F. Supp. 2d 208, 212 (E.D.N.Y. 1998). Mountainside is not asking the Court to vacate or modify the arbitrators’ award; instead, it is asking the Court to confirm the award and then add prejudgment interest to it pursuant to 9 V.S.A. § 41a(a) based on the arbitrators’ determination that the issue of interest was not arbitrable. Application ¶ 10.

Analysis

Preliminarily, the parties disagree as to whether the question of awarding prejudgment interest falls within the scope of issues that should have been determined by the arbitration panel. Mountainside argues the issue is arbitrable; VMIC asserts that it is not. On the merits of the interest issue, the parties dispute the meaning of “extra-contractual,” as that term is used in the Agreement, and whether this term covers Mountainside’s claim for pre-award interest.2 They also clash as to whether Mountainside had complied with the terms of the Policy before the parties submitted Mountainside’s claim to arbitration and was, therefore, entitled to the benefits the arbitrators awarded it before the arbitrators heard the parties’ evidence and entered the award.

courts to enforce the FAA. Shahi, 2006 VT 29, ¶ 5, 179 Vt. at 437 (citing Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 25 (1983)). Thus, this Court has jurisdiction over the case.

2 The court uses the terms “prejudgment interest” and “pre-award interest” interchangeably to mean the same thing.

The parties, thus, raise three issues: (1) whether the question of Mountainside’s entitlement to prejudgment interest is rightly subject to arbitration; (2) whether Mountainside’s claim for prejudgment interest is “extra-contractual,” as that term is used in the Agreement, and (3) whether Mountainside is entitled to recover prejudgment interest in this case.

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