Natasha Urena and Daniel Rodriguez, Administrators of the Estate of Juliana Rodriguez Morel v. Travelers Casualty and Surety Company of America

2024 DNH 006
CourtDistrict Court, D. New Hampshire
DecidedFebruary 2, 2024
Docket22-cv-200-PB
StatusPublished
Cited by1 cases

This text of 2024 DNH 006 (Natasha Urena and Daniel Rodriguez, Administrators of the Estate of Juliana Rodriguez Morel v. Travelers Casualty and Surety Company of America) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Natasha Urena and Daniel Rodriguez, Administrators of the Estate of Juliana Rodriguez Morel v. Travelers Casualty and Surety Company of America, 2024 DNH 006 (D.N.H. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Natasha Urena and Daniel Rodriguez, Administrators of the Estate of Juliana Rodriguez Morel Case No. 22-cv-200-PB v. Opinion No. 2024 DNH 006

Travelers Casualty and Surety Company of America

MEMORANDUM AND ORDER

This insurance declaratory judgment action stems from an underlying

action in which the plaintiff, Juliana Rodriguez Morel, received a default

judgment against her former employer for pregnancy discrimination and

wrongful termination. Rodriguez Morel filed the instant action seeking a

declaratory judgment that Travelers Casualty and Surety Company of

America, her employer’s insurer, is obligated to pay the judgment against her

employer. Travelers filed a motion to dismiss contending that Rodriguez

Morel lacks standing to bring this action and that, in any event, the claim is

untimely. I. BACKGROUND

Rodriguez Morel was employed by Mammoth Tech, Inc., an Ohio-based

corporation with branch offices in New Hampshire and California. 1 Doc. 1-1

at 43. Following her termination from the Manchester office, Rodriguez Morel

filed a complaint against Mammoth on January 15, 2021, asserting multiple

state and federal law claims for pregnancy discrimination and wrongful

discharge. Id. at 72; see Rodriguez Morel v. Mammoth Tech, Inc., 21-cv-40-

AJ. Rodriguez Morel ultimately obtained a default judgment in that action

for $303,592.20. Doc. 20-3 at 2.

On May 2, 2022, Rodriguez Morel filed this action against Travelers,

seeking a declaration that an employment practices liability insurance policy

(EPL policy) issued to Mammoth by Travelers obligates Travelers to pay the

default judgment against Mammoth. 2 Doc. 1-1 at 5. The complaint was

originally filed in New Hampshire state court and then removed to this court

on the basis of diversity. Doc. 1 at 1. Travelers has filed a motion to dismiss

1 Mammoth was known by a different name when Rodriguez Morel worked there. Doc. 20-3 at 1. I refer to the company by its current name throughout this order.

2 Rodriguez Morel passed away a few months after filing this action, and the co-administrators of her estate were substituted as parties pursuant to Federal Rule of Civil Procedure 25. Doc. 13. For the sake of clarity, I refer throughout this order to the original plaintiff, Rodriguez Morel, rather than the co-administrators of her estate.

2 Rodriguez Morel’s complaint pursuant to Federal Rule of Civil Procedure

12(b)(6).

II. STANDARD OF REVIEW

To survive a motion to dismiss based on Rule 12(b)(6), a plaintiff must

make factual allegations sufficient to “state a claim to relief that is plausible

on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl.

Corp. v. Twombly, 550 U.S. 544, 570 (2007)). This standard “demands more

than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. A

claim is facially plausible if it “pleads factual content that allows the court to

draw the reasonable inference that the defendant is liable for the misconduct

alleged.” Id.

In testing a complaint's sufficiency, the court employs a two-step

approach. See Ocasio–Hernández v. Fortuño-Burset, 640 F.3d 1, 12 (1st Cir.

2011). First, the complaint is screened for statements that “merely offer legal

conclusions couched as fact or threadbare recitals of the elements of a cause

of action.” Id. (cleaned up). A claim consisting of little more than “allegations

that merely parrot the elements of the cause of action” may be dismissed. Id.

Second, after crediting as true all non-conclusory factual allegations and the

reasonable inferences drawn from those allegations, the court determines if

the claim is plausible. Id. The plausibility requirement “simply calls for

enough fact to raise a reasonable expectation that discovery will reveal

3 evidence” of illegal conduct. Twombly, 550 U.S. at 556. The “make-or-break

standard” is that those allegations and inferences, “taken as true, must state

a plausible, not a merely conceivable, case for relief.” Sepúlveda–Villarini v.

Dep't of Educ. of P.R., 628 F.3d 25, 29 (1st Cir. 2010).

III. ANALYSIS

The parties disagree as to whether this case is governed by Ohio law or

New Hampshire law. If Ohio law applies, Travelers argues that Rodriguez

Morel’s action is barred because Ohio does not permit a direct action against

a wrongdoer’s insurer unless she has suffered bodily injury or property

damage. If New Hampshire law applies, it argues that Rodriguez Morel

cannot sue Travelers both because she lacks standing to sue and because her

claim is barred by New Hampshire’s six-month statute of limitations for

insurance coverage actions. I resolve the choice of law problem before turning

to the merits.

A. Choice-of-Law Analysis

“A federal court sitting in diversity jurisdiction must employ the choice-

of-law principles of the forum state . . . .” Auto Europe, LLC v. Conn. Indem.

Co., 321 F.3d 60, 64 (1st Cir. 2003). Under New Hampshire’s choice-of-law

rules, a “contract is to be governed, both as to validity and performance, by

the law of the state with which the contract has its most significant

relationship.” Consol. Mut. Ins. Co. v. Radio Foods Corp., 108 N.H. 494, 496

4 (1968). In the context of insurance contracts, “the State which is the

‘principal location of the insured risk’ bears the most significant relationship

to the contract.” Glowski v. Allstate Ins. Co., 134 N.H. 196, 198 (1991)

(quoting Ellis v. Royal Ins. Co., 129 N.H. 326, 331 (1987)). Where, however, “a

policy covers risks in more than one state, it is considered a multiple risk

policy, and the principal location of the insured risk may be in more than one

state.” Cadell v. XL Specialty Ins. Co., No. 11-cv-394-JD, 2012 WL 2359975,

at *2 (D.N.H. June 20, 2012). In such a case, each individual risk is “treated

as though it were insured by a separate policy,” and the policy is governed by

the laws of the state where the individual risk at issue is located. Cecere v.

Aetna Ins. Co., 145 N.H. 660, 664 (2001) (quoting Ellis, 129 N.H. at 331);

accord Restatement (Second) of Conflict of Laws § 193 cmt. f (noting that

“multiple risk policies which insure against risks located in several states”

may be treated “as if it involved [multiple] policies, each insuring an

individual risk”).

Rodriguez Morel asserts that the EPL policy is a multiple risk policy

that should be interpreted according to the law of New Hampshire, the place

where the risk giving rise to her claims was located. Travelers asserts that

the policy is not a multiple risk policy because “there is no indication that the

[policy] extended to risks outside of Ohio.” Doc. 24 at 2.

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