Ohio Security Insurance Company v. Veteran Construction Services, LLC

CourtDistrict Court, D. Connecticut
DecidedJanuary 10, 2025
Docket3:23-cv-00257
StatusUnknown

This text of Ohio Security Insurance Company v. Veteran Construction Services, LLC (Ohio Security Insurance Company v. Veteran Construction Services, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ohio Security Insurance Company v. Veteran Construction Services, LLC, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT OHIO SECURITY INSURANCE CO., ) 3:23-cv-257 (SVN) Plaintiff, ) ) v. ) ) VETERAN CONSTRUCTION ) SERVICES, LLC, et al., ) Defendants. ) January 10, 2025 JOINT RULING AND ORDER ON PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT AND MOTION FOR SUMMARY JUDGMENT Sarala V. Nagala, United States District Judge. Plaintiff Ohio Security Insurance Company (“Ohio”) seeks a declaratory judgment that it has no duty to defend or indemnify Defendant Veteran Construction Services, LLC (“Veteran”) for any damages claimed in two lawsuits resulting from a tragic workplace accident that killed Joseph O’Donnell and Euel Sims on November 13, 2020 (the “Underlying Actions”). The plaintiffs in the Underlying Actions—Christina Weaver, as administratrix of O’Donnell’s estate, and Cynthia Petrie, as executrix of Sims’s estate—are also named as Defendants. Ohio previously moved for default judgment against Veteran and summary judgment against Weaver and Petrie;1 the Court denied these motions, finding that it was appropriate to decline to exercise its jurisdiction to issue a declaratory judgment as to Ohio’s duty to defend because there was no justiciable controversy related to Ohio’s duty to indemnify. See Orders, ECF Nos. 59, 60. In response, Ohio filed an amended complaint and now renews its motion for default

1 Although Ohio did not specify that its motion for summary judgment was brought against only Weaver and Petrie, the Court construes it as such, given that Ohio was also seeking a default judgment against Veteran. See Pl.’s Mot. Summ. J., ECF No. 44. The Court likewise construes Ohio’s renewed motion for summary judgment, see Pl.’s Renewed Mot. Summ. J., ECF No. 65, as being brought against Weaver and Petrie only, for the same reason. judgment against Veteran, see Pl.’s Renewed Mot. Default J., ECF No. 64, as well as its motion for summary judgment against Weaver and Petrie. See ECF No. 65. For the reasons described below, the Court grants default judgment in part against Veteran, declaring that Ohio has no duty to defend or indemnify Veteran in the underlying Petrie action,

but denies default judgment against Veteran with respect to the underlying Weaver action. Ohio’s motion for summary judgment is likewise granted in part as to Defendant Petrie, and denied as moot as to Weaver. I. PROCEDURAL BACKGROUND The Court assumes the parties’ familiarity with its order adopting in part Magistrate Judge Garcia’s recommended ruling on Ohio’s motion for default judgment and denying Ohio’s motion for default judgment without prejudice. See Ohio Sec. Ins. Co. v. Veteran Constr. Servs., LLC, No. 3:23-CV-257 (SVN), 2024 WL 1287583 (D. Conn. Mar. 26, 2024). Accordingly, the Court discusses only the additional procedural background necessary for this ruling. As relevant here, Ohio issued two commercial general liability policies to Veteran. The

first policy began on October 10, 2017, and ran through October 10, 2018, while the second policy began on October 10, 2018, and was set to run through to October 10, 2019 (collectively, the “Policies”). Am. Compl., ECF No. 63 ¶¶ 11–12. The second policy period was ultimately canceled for non-payment as of October 10, 2018. Id. ¶ 13. The policies included the same relevant language regarding the scope of coverage for injuries. Id. ¶¶ 15–21. Coverage A pertained to bodily injury and property damage, id. ¶ 16; Coverage B applied to personal and advertising injury. Id. ¶ 18. The coverages are discussed further below. The Underlying Actions arise from a fatal workplace incident. Id. ¶¶ 22–38. They allege that Sims, an employee of the Department of Veterans Affairs, and O’Donnell, an employee of Mulvaney Mechanical, Inc., were killed as a result of a steam pipe rupture at the Department of Veterans Affairs hospital campus in West Haven, Connecticut on November 13, 2020. Id. ¶¶ 23– 27, 32–36. Weaver and Petrie allege that Veteran’s negligence in, among other things, improperly installing the steam valves, caused the deaths of Mr. O’Donnell and Mr. Sims. Id. ¶ 29. The

Underlying Actions allege claims against Veteran for wrongful death and loss of consortium. Id. ¶¶ 28, 30, 37–38. The underlying Weaver action has been closed since February of 2024, while the underlying Petrie action remains pending. Weaver et al. v. USA, No. 3:22-cv-352 (JCH) (D. Conn. 2022), ECF No. 111; Cynthia Petrie, Ex’x of the Est. of Euel T., et al. v. Mulvaney Mech. Inc., No. HHD-CV22-6179070-S (Conn. Super. Ct. 2022), Dkt. No. 115.00. Veteran has never appeared in this action, despite being properly served. The Court nonetheless denied Ohio’s first motion for default judgment against Veteran without prejudice; it declined to exercise jurisdiction to issue a declaratory judgment related to Ohio’s potential duty to defend Veteran because Ohio had not pleaded facts demonstrating that Veteran had sought insurance coverage from Ohio, and found that Ohio’s request for a declaratory judgment related

to its potential duty to indemnify was not justiciable at that time. Ohio Sec. Ins. Co., 2024 WL 1287583, at *6–8. Ohio then filed an amended complaint on May 1, 2024, in which it added factual allegations regarding Veteran’s efforts to seek coverage from Ohio. See Am. Compl. ¶¶ 39–45. Specifically, Ohio alleges that on December 5, 2022, Veteran submitted a claim to Ohio in connection with the Underlying Actions; in response, Ohio advised Veteran that the loss occurred outside the policy period of its policies, and recommended that Veteran reach out to the carrier that issued the policy in force on the date of the loss. Id. ¶¶ 39–40. On December 23, 2022, Ohio issued a formal disclaimer letter to Veteran, stating Ohio has no duty to defend and/or indemnify Veteran in the Underlying Actions. Id. ¶ 41. On January 3, 2023, counsel for Veteran contested Ohio’s coverage position and argued that Veteran’s allegedly negligent acts occurred in July of 2018, which would fall under the coverage period of the first Ohio policy, effective October 10, 2017, through October 10, 2018. Id. ¶¶ 11, 42–43. On January 23, 2023, Ohio issued a supplemental disclaimer letter to Veteran, arguing that it has no duty to defend and/or indemnify

Veteran under Coverage A and/or Coverage B of the policy, because the explosion and subsequent deaths occurred outside the policy period and that, even if the loss occurred within the policy period, coverage would be excluded under several exclusions within the policy. Id. ¶¶ 44–45. The day after filing its amended complaint, Ohio filed a renewed motion for default judgment against Veteran pursuant to Rule 55(b)(2). ECF No. 64. Ohio makes the same two arguments it previously made in support of its request for a default judgment. First, Ohio contends that, under Coverage A, Ohio owes no duty to defend or indemnify Veteran because the decedents’ deaths did not occur during the relevant policy periods. Id. at 2. Second, Ohio argues that, under Coverage B, Ohio owes no duty to defend or indemnify Veteran because neither Underlying Action alleges a “personal and advertising injury” that would trigger Coverage B. Id.

On the same day it filed its renewed motion for default judgment, Ohio separately renewed its motion for summary judgment, making essentially the same arguments it makes in its default judgment motion against Veteran. ECF No. 65. As noted above, the Court construes the motion for summary judgment as being brought against Weaver and Petrie only. Neither Weaver nor Petrie have responded to Ohio’s renewed motion for summary judgment. The status of the Underlying Actions is as follows. The underlying Weaver action, in which Veteran was sued and appeared through its principal but did not otherwise participate, is closed. Following a report of settlement, the action was dismissed on February 16, 2024. Weaver, No. 3:22-cv-352 (JCH), ECF Nos. 59, 111.

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Bluebook (online)
Ohio Security Insurance Company v. Veteran Construction Services, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ohio-security-insurance-company-v-veteran-construction-services-llc-ctd-2025.