Neat Sweep of Richmond, Inc. v. National Chimney Sweep Guild

20 Va. Cir. 274, 1990 Va. Cir. LEXIS 145
CourtRichmond County Circuit Court
DecidedJuly 10, 1990
DocketCase No. LM-2799-3
StatusPublished

This text of 20 Va. Cir. 274 (Neat Sweep of Richmond, Inc. v. National Chimney Sweep Guild) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Neat Sweep of Richmond, Inc. v. National Chimney Sweep Guild, 20 Va. Cir. 274, 1990 Va. Cir. LEXIS 145 (Va. Super. Ct. 1990).

Opinion

By JUDGE T. J. MARKOW

This matter is before the court on defendant’s motion for partial summary judgment. Defendant attacks Count I of the motion for judgment which bases a cause of action on alleged violations of §§ 38.2-502 and 38.2-503 of the Code of Virginia (a part of the Virginia Unfair Insurance Practices Act).

I. Facts

Briefly, this case centers around the sale of allegedly bogus liability insurance policies to members of the defendant trade association by a Massachusetts insurance agent (Ryan). Defendant sought to make available low cost insurance for its members, and Ryan agreed to provide that coverage by issuance of the allegedly bogus policies. Availability of the insurance was advertised in defendant’s trade magazine, which was distributed to its members, including plaintiff. Plaintiff, in reliance upon one of the ads, purchased a worthless policy from Ryan. Plaintiff claims that when he was notified that the coverage was nonexistent, he was unable to obtain other coverage and had to forego income producing activity, and claims damages as a result.

[275]*275II. Analysis

A. Arguments

In paragraphs 16 and 17 of the motion for judgment, plaintiff complains of alleged conduct by defendant which violated Chapter 5 of the Code of Virginia (Unfair Trade Practices Act) of Title 38.2, entitled "Insurance."

Specifically, plaintiff alleges that defendant violated Sections 38.2-502 and 38.2-503 of the Code, which read:

Section 38.2-502. Misrepresentations and false advertising of insurance policies. — No person shall make, issue, circulate, cause or knowingly allow to be made, issued or circulated, any estimate, illustration, circular, statement, sales presentation, omission, or comparison that:
1. Misrepresents the benefits, advantages, conditions or terms of any insurance policy;
2. Misrepresents the dividends or share of the surplus to be received on any insurance policy;
3. Makes any false or misleading statements as to the dividends or share of surplus previously paid on any insurance policy;
4. Misrepresents or is misleading as to the financial condition of any person or the legal reserve system upon which any life insurer operates;
5. Unless any name or title of any insurance policy or class of insurance policies that misrepresents the true nature of the policy or policies;
6. Misrepresents for the purpose of inducing or tending to induce the lapse, forfeiture, exchange, conversion, or surrender of any insurance policy;
7. Misrepresents for the purpose of effecting a pledge, assignment, or loan on any insurance policy; or
8. Misrepresents any insurance policy as being a share of stock.

[276]*276and

Section 38.2-503. False information and advertising generally. — No person shall knowingly make, publish, disseminate, circulate, or place before the public, or cause or knowingly allow, directly or indirectly, to be made, published disseminated, circulated, or placed before the public in a newspaper, magazine, other publication, or in the form of a notice, circular, pamphlet, letter or poster, or ovér any radio or television station, or in any other way, an advertisement, announcement or statement containing any assertion, representation or statement relating to (i) the business of insurance or (ii) any person in the conduct of his insurance business, which is untrue, deceptive or misleading.

Va. Code Ann. §§ 38.2-502 and 38.2-503 (1989 Cum. Supp.).

Defendant argues that these provisions are regulatory in nature and are directed toward the State Corporation Commission. Defendant correctly states that the regulatory nature of the act was intended to create in the commission the "power to examine and investigate the affairs of each person subject to the act," Va. Code Ann. § 38.2-515 (1989 Cum. Supp.); See also Va. Code Ann. § 38.1-53 (1981 Repl. Vol.) (Identical statute in previous codification). A & E Supply Co. v. Nationwide Mutual Fire Insurance Co., 798 F.2d 669 (4th Cir. 1986). Defendant argues that the Unfair Insurance Practices Act does not establish a private cause of action. In A & E the Fourth Circuit Court of Appeals stated "It is clear that the Virginia Supreme Court would not read the Unfair Insurance Practices Act to create a private right of action in tort." Id. at 674.

The question then becomes whether A & E is convincing authority, as it so squarely addresses the issue before this court.

[277]*277B. A & E Supply Company v. Nationwide

Plaintiff attempts to discredit the A & E decision by citing cases, which predate A & E, from the U.S. Supreme Court and other circuit courts.

Despite the source of the authority cited, plaintiff’s arguments are not convincing. None of its cases addresses the question of a private cause of action arising in the context of a Virginia statute that does not purport to do so. None of plaintiff’s cases arose out of similar facts or Virginia law, and, in fact, most were constructions of federal law. See, e.g., Cort v. Ash, 422 U.S. 66 (1975). The same analysis applies to plaintiff’s authority from the United States Supreme Court. In order to successfully attack the persuasiveness of A & E, plaintiff would have to give authority more closely factually related to the instant case.

Furthermore, the court of appeals in A & E can be assumed to have been aware of those cases cited by plaintiff, as they predate the A & E decision by several years. Despite those decisions, however, the Fourth Circuit applied an analysis particularized to Virginia law. As stated before, this court finds that federal decisions based upon interpretations of non-Virginia federal law are not instructive where the effect of a Virginia statute is in question, and specifically addressed by a court of appeals decision. See A & E, 798 F.2d 669, 674.

C. Statute Re-enactment

Plaintiff’s argument that a statute, once construed and then re-enacted without change approves that construction, is also unconvincing. Plaintiff argues that the General Assembly re-enacted the Unfair Insurance Practices Act under title 38.1 of the Code as Title 38.2 after the district court decision in A & E Supply Co. v. Nationwide Mutual Fire Ins. Co., 612 F. Supp. 760 (W.D. Va. 1985), but before reversal by the court of appeals. 798 F.2d 669 (4th Cir. 1986).

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Related

Cort v. Ash
422 U.S. 66 (Supreme Court, 1975)
Commonwealth v. County Board of Arlington County
232 S.E.2d 30 (Supreme Court of Virginia, 1977)
A & E Supply Co. v. Nationwide Mutual Fire Insurance
612 F. Supp. 760 (W.D. Virginia, 1985)
State v. Williams
21 S.E. 721 (West Virginia Supreme Court, 1895)
Miller v. Commonwealth
80 Va. 33 (Supreme Court of Virginia, 1885)

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20 Va. Cir. 274, 1990 Va. Cir. LEXIS 145, Counsel Stack Legal Research, https://law.counselstack.com/opinion/neat-sweep-of-richmond-inc-v-national-chimney-sweep-guild-vaccrichmondcty-1990.