Osborne v. Paris

CourtCourt of Appeals of North Carolina
DecidedMay 17, 2022
Docket21-226
StatusPublished

This text of Osborne v. Paris (Osborne v. Paris) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Osborne v. Paris, (N.C. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

2022-NCCOA-338

No. COA21-226

Filed 17 May 2022

Henderson County, No. 20 CVS 517

RACHEL LYNNE OSBORNE, Plaintiff,

v.

HEATH PARIS, JORDAN ASHWORTH and GOVERNMENT EMPLOYEES INSURANCE COMPANY, Defendants.

Appeal by Plaintiff from judgment entered 11 September 2020 by Judge Peter

B. Knight in Henderson County Superior Court. Heard in the Court of Appeals 15

December 2021.

Whitfield-Cargile Law, PLLC, by Davis A. Whitfield-Cargile, for Plaintiff- Appellant.

Davis & Hamrick, L.L.P., by James G. Welsh, Jr., and Ann C. Rowe, for Defendant-Appellee.

INMAN, Judge.

¶1 This appeal arises from a dispute between an insured and her insurance

provider over motor vehicle liability insurance coverage for grave injuries she

sustained in a collision between an uninsured motorcycle, on which she was a

passenger, and an underinsured car. Resolving the disagreement requires us to apply

North Carolina statutes to three automobile insurance policies, two providing OSBORNE V. PARIS

Opinion of the Court

uninsured motorist coverage, and one providing combined uninsured and

underinsured motorist coverage. After careful review of the insurance policies at

issue, the Motor Vehicle Safety and Financial Responsibility Act (“Financial

Responsibility Act”), and our caselaw, we affirm the trial court’s entry of summary

judgment in favor of Defendant-Appellee Government Employee’s Insurance

Company (“GEICO”), in part, but modify the amount GEICO must pay Ms. Osborne

because it was not entitled to a credit against its uninsured motorist coverage.

¶2 Plaintiff-Appellant Rachel Osborne (“Ms. Osborne”) argues that the trial court

erred in granting summary judgment in favor of GEICO on her claim for $70,000 in

underinsured motorist coverage in addition to $100,000 of uninsured motorist

coverage. Ms. Osborne contends her right to recover underinsured motorist coverage

was triggered when GEICO tendered Defendant Jordan Ashworth’s (“Mr. Ashworth”)

liability limits to Ms. Osborne, and that the Financial Responsibility Act, N.C. Gen.

Stat. §§ 20-279.21(b)(3) and (4) (2021), does not allow GEICO to reduce the $160,000

uninsured motorist coverage by its payment of Mr. Ashworth’s $30,000 liability limit.

Ms. Osborne also argues the trial court erred in granting summary judgment to

GEICO on her claims of bad faith and unfair trade practices.

I. FACTUAL & PROCEDURAL BACKGROUND

¶3 On the night of 4 April 2017, Ms. Osborne was a passenger on a motorcycle on

Crab Creek Road in Transylvania County, traveling toward Brevard. The motorcycle OSBORNE V. PARIS

was operated by its owner, Defendant Heath Paris (“Mr. Paris”). Ahead of Mr. Paris

on the same road, Mr. Ashworth was driving his car, also headed toward Brevard. As

Mr. Ashworth approached an intersection, he allegedly signaled to turn right and

slowed his vehicle as if he was pulling over on the shoulder of the road. Anticipating

the car’s right turn, Mr. Paris attempted to pass on the car’s left, in a non-passing

zone. At the same time, Mr. Ashworth turned left, instead of right, and the

motorcycle and car collided. The impact sent the motorcycle airborne. Ms. Osborne

was ejected and landed on the ground a great distance from the motorcycle. She

sustained serious injuries requiring several surgeries and other extensive medical

treatment, and her injuries will require future surgeries and treatment.

¶4 Mr. Paris’ motorcycle was uninsured, meaning no policy of liability insurance

existed to provide coverage for the motorcycle or for Mr. Paris as a driver. Mr.

Ashworth’s car was insured by a liability insurance policy through GEICO, with

minimum-limits bodily injury liability coverage of $30,000 per person. It is

undisputed Mr. Ashworth’s vehicle is an “underinsured motor vehicle” as defined by

the Financial Responsibility Act.

¶5 GEICO tendered $30,000 to Ms. Osborne under Mr. Ashworth’s policy on 6

March 2020.

¶6 Three days later, on 9 March 2020, Ms. Osborne, through counsel, sent a

written demand to GEICO for $160,000 of uninsured motorist coverage and $70,000 OSBORNE V. PARIS

of underinsured motorist coverage under three different GEICO policies. Her own

liability insurance policy with GEICO, Policy no. 4416-06-95-42 (“Policy 42”),

provided uninsured motorist coverage up to $30,000 per person. Because Ms.

Osborne lived in the same household as her parents, Bobby and Ginger Osborne, she

was also covered by their policies with GEICO. Policy no. 4325-46-40-65 (“Policy 65”),

which covers two vehicles, neither of which were involved in the underlying accident,

provides combined uninsured and underinsured bodily injury liability coverage of

$100,000 per person and a total limit of $300,000 per accident. Policy 65 provides

that the “limit of bodily injury liability shown in the Declarations for each accident

for Combined Uninsured/Underinsured Motorists Coverage is [the] maximum limit

of liability for all damages for bodily injury resulting from any one accident.” Ms.

Osborne also claims she is entitled to coverage under Policy no. 4325-46-67-06 (“Policy

06”), which insures a single motorcycle owned by Ms. Osborne’s parents and not

involved in the underlying accident. Policy 06 provides limits of liability for

uninsured motorist bodily injury liability of $30,000 for each person, with a total limit

of $60,000 per accident.

¶7 On 13 March 2020, four days after Ms. Osborne formally demanded payment

from GEICO, she filed suit against Mr. Paris and Mr. Ashworth, alleging negligence,

as well as GEICO, alleging GEICO had: (1) breached its obligation to pay

underinsured motorist benefits and uninsured motorist benefits to her; (2) displayed OSBORNE V. PARIS

bad faith in its refusal to settle with Ms. Osborne on reasonable terms; and (3)

engaged in unfair and deceptive trade practices. Ms. Osborne alleged that because

Mr. Paris was uninsured, she was entitled to benefits under her policy’s uninsured

coverage, uninsured coverage under her parents’ motorcycle policy, and uninsured

coverage of her parents’ automobile policy. She also alleged she was entitled to an

additional $100,000 in underinsured coverage under her parents’ automobile policy,

Policy 65, because Mr. Ashworth was an underinsured motorist.

¶8 On 6 April 2020, GEICO remitted to Ms. Osborne three checks totaling

$130,000––$100,000 combined uninsured/underinsured coverage under Policy 65,

$15,000 uninsured coverage under Policy 42, and $15,000 uninsured coverage under

Policy 06.1 GEICO’s counsel asserted Ms. Osborne was entitled to $130,000 of

uninsured motorist coverage, the total available coverage of $160,000 under all three

policies, less a $30,000 credit for the amount paid to Ms. Osborne under Mr.

Ashworth’s liability policy. GEICO contends this credit is required by its policy

language providing that “coverage shall be reduced by all sums . . . [p]aid because of

bodily injury . . . by or on behalf of persons or organizations who may be legally

responsible . . . .”

1 As explained in further detail below, the amounts GEICO paid under Policies 42 and 06 reflect a pro rata credit distribution of the $30,000 from Mr. Ashworth’s policy. OSBORNE V. PARIS

¶9 One month later, on 12 May 2020, GEICO responded to Ms. Osborne’s

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