NL Corp., Inc. v. Seneca Specialty Ins. Co.

2021 Ohio 1610
CourtOhio Court of Appeals
DecidedMay 7, 2021
Docket28927
StatusPublished

This text of 2021 Ohio 1610 (NL Corp., Inc. v. Seneca Specialty Ins. Co.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
NL Corp., Inc. v. Seneca Specialty Ins. Co., 2021 Ohio 1610 (Ohio Ct. App. 2021).

Opinion

[Cite as NL Corp., Inc. v. Seneca Specialty Ins. Co., 2021-Ohio-1610.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT MONTGOMERY COUNTY

: NL CORP., INC. : : Appellate Case No. 28927 Plaintiff-Appellant : : Trial Court Case No. 2017-CV-1767 v. : : (Civil Appeal from SENECA SPECIALTY INSURANCE : Common Pleas Court) COMPANY : : Defendant-Appellee

...........

OPINION

Rendered on the 7th day of May, 2021.

DANIEL J. KNECHT, Atty. Reg. No. 0086463, 312 Walnut Street, Suite 1800, Cincinnati, OH 45202 Attorney for Plaintiff-Appellant

MATTHEW J. BAKOTA, Atty. Reg. No. 0079830, 1 South Main Street, Suite 1300, Dayton, Ohio 45402 Attorney for Defendant-Appellee

.............

HALL, J. -2-

{¶ 1} NL Corp., Inc. appeals from the trial court’s summary judgment in favor of

Seneca Specialty Insurance Company on NL’s claims for breach of an insurance policy

and bad faith. After a man fell in NL’s parking lot and later died, his family made a claim

to Seneca, NL’s insurer, and Seneca settled the claim within the limits of NL’s policy. NL

contended that Seneca’s wrongful conduct in handling the matter required NL to retain

an attorney, and that Seneca refused to reimburse NL for the attorney’s fees and costs.

NL also appeals from the trial court’s granting summary judgment on Seneca’s

counterclaim for the deductible owed under the insurance policy, which NL had refused

to pay. Seneca contended that, because it paid the claim, NL was obligated to pay the

deductible. At least one claim remains pending in the trial court, but the trial court’s

granted Civ.R. 54(B) certification with respect to its judgment on the claims listed above.

{¶ 2} We conclude that the trial court did not err. Seneca’s contractual duty to

defend NL was never triggered because no “suit” for damages was ever filed against NL.

Consequently, Seneca was not obligated to pay the fees and costs of the attorney that

NL voluntarily retained. Further, Seneca did not act in bad faith in its handling of the

matter. And, because Seneca paid the claim, NL is obligated to pay the required

deductible. Accordingly, we affirm the trial court’s judgment.

I. Factual and Procedural Background

{¶ 3} NL operates a nightclub in the Dayton area. On May 11, 2014, a patron at

the club, Adam Bishop, fell in the parking lot after a confrontation with club security and

struck his head on the pavement; he died several days later. The police took witness

statements and prepared a police report, and the police were given surveillance video -3-

that had recorded Bishop’s fall.

{¶ 4} Fearing criminal and civil liability, NL retained attorney Scott Jones. About a

month after the incident, NL reported the incident to its insurance company, Seneca. Four

days later, Seneca Senior Claims Examiner Monica Chu hired Rick Watson to investigate

the incident in order to help Seneca make coverage determinations. According to Chu,

Watson was told by Jones that he (Watson) could not take any witness statements or

obtain the police report. Four months later, Watson was finally able to do a site inspection,

but he was still prevented from taking witness statements or obtaining the police report

relating to the incident. According to Jones, he wanted Watson’s interviews with

witnesses delayed because he was concerned that the witnesses’ statements would not

be privileged and because he wanted to avoid creating a record that could conflict with

statements already collected by the police. NL finally gave Seneca the surveillance tape

in July 2014 and the police report in December 2014.

{¶ 5} In late 2014, Thomas Schwartz, an attorney for the Bishop family, contacted

both NL and Seneca about the incident. Schwartz did not assert any claims or make any

requests during this initial contact. In January 2015, Schwartz again discussed the

incident with Seneca, and Schwartz agreed to send Seneca documentation of the family’s

claims related to Bishop’s death. Schwartz also had written communication with Jones

(NL’s attorney) in which he suggested that NL was underinsured and that NL might be

responsible for payment. On February 4, 2015, at Jones’s insistence, Seneca sent Jones

a letter outlining its preliminary coverage position; the letter stated that the $250,000

assault-and-battery limit under the policy may apply to the claim and indicated that NL

had not cooperated with Seneca’s investigation of the claim. -4-

{¶ 6} Seneca maintained that it had no obligation to pay for counsel for NL,

because no suit had been filed. Nevertheless, at Jones’s insistence, Seneca appointed

attorney David Ross to represent NL in the investigation. But NL was not satisfied. It

wanted separate counsel, unbeholden to Seneca, because NL was concerned about a

potential conflict of interest between it and Seneca in the event that the Bishop family

brought a claim for an intentional tort or over-the-limit coverage questions arose. The

relationship between NL and Ross proved unworkable.

{¶ 7} In May 2015, Schwartz sent Seneca documents supporting the Bishop

family’s claim for wrongful death. Two months later, Schwartz proposed to settle the claim

for $250,000 and the release of NL from all further liability. Part of the settlement required

NL to provide an affidavit stating that the Seneca policy was the only one that it held that

provided coverage for the incident. In August, Seneca agreed to the proposed settlement.

Chu, the claims examiner, told NL’s attorney, Jones, in an email that any work he did on

the settlement would be at NL’s expense. Nevertheless, Jones drafted NL’s coverage

affidavit and also helped draft language in the settlement agreement.

{¶ 8} Bishop was a resident of Missouri at the time of his death, and under Missouri

law, a settlement of a wrongful-death claim had to be approved by a Missouri probate

court. A probate case was opened, and on December 15, 2015, the Bishop family’s

settlement agreement with Seneca was approved by the court. Seneca paid the family

the agreed $250,000 under the policy’s coverage for assault and battery.

{¶ 9} In April 2017, NL filed suit against Seneca, claiming that Seneca had

breached the insurance policy by refusing to reimburse it for Jones’s fees and costs. NL

alleged that it had incurred these expenses because Seneca had failed to satisfy its -5-

obligations under the policy by not adequately and timely investigating the incident. NL

further claimed that Seneca’s conduct constituted insurer bad faith. Seneca

counterclaimed that NL had refused to pay the $5,000 deductible that it owed under the

policy after Seneca made the payment to the Bishop family.

{¶ 10} Seneca moved for summary judgment on NL’s claims and on its

counterclaim for payment of the deductible. The trial court sustained Seneca’s motion.

The court concluded that Seneca had not breached the insurance policy, determining that

Seneca had no duty to defend NL because no suit seeking damages was ever filed, which

was a condition precedent to the duty to defend under the policy. The court also

concluded that Seneca did not breach the policy with respect to its investigation of the

incident. The court found that the policy left investigation of an incident to Seneca’s

discretion; the policy permitted Seneca to conduct an investigation but did not require

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2021 Ohio 1610, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nl-corp-inc-v-seneca-specialty-ins-co-ohioctapp-2021.