National Casualty Company v. Sotelo

CourtDistrict Court, D. Nevada
DecidedSeptember 23, 2020
Docket2:17-cv-02456
StatusUnknown

This text of National Casualty Company v. Sotelo (National Casualty Company v. Sotelo) 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
National Casualty Company v. Sotelo, (D. Nev. 2020).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 * * *

7 NATIONAL CASUALTY CO., a Wisconsin Case No. 2:17-cv-02456-KJD-CWH corporation, 8 ORDER DENYING DEFENDANT’S Plaintiff, MOTION FOR SUMMARY JUDGMENT 9 AND MOTION TO DISMISS v. 10 EFREN ISAAC SOTELO, an individual; and 11 PHILIP MICHAEL BOUCHARD, an individual, 12 Defendants. 13

14 This is an action for declaratory relief with respect to an insurance policy issued by 15 16 Plaintiff National Casualty Company (“NCC”). Presently before the Court are Defendant Philip 17 Michael Bouchard’s (“Bouchard”) Motion for Summary Judgment (#74) and Motion to Dismiss 18 (#77). Plaintiff responded (#79/80) to which Defendant replied (#82/85). 19 I. Factual and Procedural History 20 In July 2016, Bouchard filed a negligence suit in state court after suffering injuries in a 21 22 car accident with Efren Sotelo (“Efren”). (#74 at 4). Efren was driving a pick-up truck owned by 23 his father, Juan Sotelo’s (“Juan”) company Now Services of Nevada, LLC dba Cool Air Now 24 (“Cool Air”). Id. Plaintiff provided commercial automobile insurance to Cool Air. (#1 at 2). The 25 policy covered as insureds the named insured and “anyone else while using with [the named 26 insured’s] permission a covered ‘auto.’” Id. at 3. Whether Efren was a permissive user of the 27 28 truck is the main issue in this case. NCC alleges that Efren was not a permissive user because he 1 was driving a stolen truck after Cool Air fired him two days prior to the accident. Id. Juan filed a 2 police report for the stolen truck on the day of the accident. Id. at 4. Bouchard alleges Efren was 3 a permissive user because his termination paperwork shows that his final day of work would 4 have been after the day of the accident. (#74 ex. 5). Because NCC alleged that Efren did not have 5 6 permission to use the truck, it did not defend him in the original state court action. (#1 at 4). 7 Efren failed to respond to the complaint and the state court entered default judgment against him. 8 Id. NCC filed this suit seeking declaratory judgment in September 2017. Id. at 5. 9 This Court stayed the proceedings pending resolution of the state action in April 2019. 10 (#65). The question of whether Efren was a permissive user of the truck and therefore whether 11 12 NCC owed Efren a duty to defend and indemnify would have been resolved during that trial. Id. 13 at 2. However, Bouchard dismissed Juan and Cool Air the day before trial began. (#80 at 2). 14 Without Juan and Cool Air as parties, the state court could not answer the permissive use 15 question. Id. In April 2019, after receiving the default judgment, Bouchard filed a complaint in 16 state court alleging breach of contract, breach of implied covenants of good faith and fair 17 18 dealing, and declaratory judgment against NCC, another insurance company, and two law firms. 19 (#87-1). The claims arose from the same set of facts as the original action and NCC’s alleged bad 20 faith in not defending Efren. Id. 21 II. Legal Standard 22 Declaratory judgment allows the Court to adjudicate a party’s rights or obligations before 23 24 it seeks a coercive remedy. Seattle Audubon Soc’y v. Moseley, 80 F.3d 1401, 1405 (9th Cir. 25 1996). However, the Declaratory Judgment Act does not expand the Court’s jurisdiction. Id.; see 26 also Skelly Oil Co. v. Phillips Petroleum Co., 339 U.S. 667 (1950). Rather, a claim for 27 declaratory relief is subject to the same federal jurisdictional requirements as any other case; it 28 1 must be “brought by [an] interested party,” and it must involve an actual controversy. See 28 2 U.S.C. § 2201; Moseley, 80 F.3d at 1405. A declaratory judgment action that seeks clarification 3 of an insurer’s coverage obligation or duty to defend is ripe for judicial review. See Govt. Emp.s 4 Ins. Co. v. Dizol, 133 F.3d 1120, 1222 n.2 (9th Cir. 1998); AAA Nev. Ins. Co. v. Chau, No. 5 6 2:08-cv-00827-RCJ-LRL, 2010 WL 1756986, at *3 (D. Nev. Apr. 30, 2010). 7 Summary judgment is appropriate where there exists no genuine issue of fact and when 8 the moving party is entitled to judgment as a matter of law. See Fed. R. Civ. P. 56(a); Celotex 9 Corp. v. Catrett, 477 U.S. 317, 322 (1986). The moving party bears the burden of showing the 10 absence of genuine issues of material fact. Celotex, 477 U.S. at 323. The burden then shifts to the 11 12 nonmoving party to show specific facts demonstrating a genuine factual dispute for trial. See 13 Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986). The Court makes 14 all justifiable inferences in favor of the nonmoving party. Matsushita, 475 U.S. at 587. However, 15 the nonmoving party may not merely rest on the allegations of his pleadings. Rather, he must 16 produce specific facts—by affidavit or other evidence—showing a genuine issue of fact. 17 18 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 256 (1986). Summary judgment is not 19 appropriate if a reasonable jury could return a verdict for the nonmoving party. Id. at 248. 20 III. Analysis 21 Defendant filed a motion to dismiss and a motion for summary judgment. The court 22 analyzes each individually. 23 24 A. Motion to Dismiss 25 When determining if a declaratory judgment action should be dismissed, “[t]he Brillhart 26 factors remain the philosophical touchstone for the district court.” Dizol, 133 F.3d at 1225. The 27 court has three main considerations: it “should avoid needless determination of state law issues; 28 1 it should discourage litigants from filing declaratory actions as a means of forum shopping; and 2 it should avoid duplicative litigation.” Id. These factors are not exhaustive, and the district court 3 may make other considerations, such as: 4 “Whether the declaratory action will settle all aspects of the controversy; whether 5 the declaratory action will serve a useful purpose in clarifying the legal relations 6 as issue; whether the declaratory action is being sought merely for the purposes of procedural fencing or to obtain a ‘res judicata’ advantage; or whether the use of a 7 declaratory action will result in entanglement between the federal and state court systems. In addition, the district court might also consider the convenience of the 8 parties, and the availability and relative convenience of other remedies.” 9 10 Dizol, 133 F.3d at 1225 n.5. The Brillhart factors and the additional considerations weigh in 11 favor of not dismissing. 12 i. Needless determination of state law issues 13 When “parallel state proceedings involving the same issues and parties [are] pending at 14 15 the time the federal declaratory action is filed, there is a presumption that the entire suit should 16 be heard in state court.” Id. When NCC filed this suit, there was a parallel state proceeding. To 17 avoid a needless determination of a state law issue, this Court stayed the case pending resolution 18 of the state law claim. However, Bouchard dismissed Juan and Cool Air which prevented the 19 state court from making the necessary state law determination. This case focuses on a single 20 21 question, whether Efren was a permissive user of the truck on the day of the accident. That 22 question would have been answered had Bouchard continued to trial. Bouchard’s actions created 23 a need for this Court to make a determination of state law.

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Related

Skelly Oil Co. v. Phillips Petroleum Co.
339 U.S. 667 (Supreme Court, 1950)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Foster v. Dingwall
227 P.3d 1042 (Nevada Supreme Court, 2010)
Five Star Capital Corp. v. Ruby
194 P.3d 709 (Nevada Supreme Court, 2008)
American Casualty Co. of Reading v. Krieger
181 F.3d 1113 (Ninth Circuit, 1999)

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National Casualty Company v. Sotelo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-casualty-company-v-sotelo-nvd-2020.