Parc Lorraine Condominium Association V. Philadelphia Indemnity Insurance Company

CourtDistrict Court, E.D. Missouri
DecidedJuly 7, 2025
Docket4:24-cv-00228
StatusUnknown

This text of Parc Lorraine Condominium Association V. Philadelphia Indemnity Insurance Company (Parc Lorraine Condominium Association V. Philadelphia Indemnity Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parc Lorraine Condominium Association V. Philadelphia Indemnity Insurance Company, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

PARC LORRAINE CONDOMINIUM ) ASSOCIATION, ) ) Plaintiff, ) ) Case No. 4:24-cv-00228-SRC v. ) ) PHILADELPHIA INDEMNITY ) INSURANCE COMPANY, )

Defendant.

Memorandum and Order In 2019, a wind-and-hail storm damaged Parc Lorraine Condominium Association’s condominium complex. Parc Lorraine sought to receive the benefits of its insurance policy, but its insurer—Philadelphia Indemnity Insurance Company—refused to pay the full claim. Parc Lorraine sued Philadelphia Indemnity, asserting breach-of-contract and vexatious-refusal-to-pay claims. Now, Philadelphia Indemnity seeks summary judgment on the vexatious-refusal-to-pay claim. I. Background The Court finds the following facts undisputed for purposes of summary judgment, most of which the parties agree are undisputed. The Court notes below the facts that the parties dispute. Parc Lorraine owns and operates a condominium complex, in St. Louis, Missouri, that consists of multiple buildings. Doc. 54 at ¶ 5(b). Between January 1, 2019, and January 1, 2020, Parc Lorraine insured its condominium complex through Philadelphia Indemnity under a commercial insurance policy. Id. at ¶ 5(a). Around July 28, 2022, Parc Lorraine submitted a claim under the policy regarding an alleged loss that it suffered at the condominium complex (damage to the buildings’ roofs) as a result of a June 26, 2019 wind-and-hail storm. Id. at ¶¶ 5(d), 5(f); doc. 57 at ¶¶ 3, 6; doc. 61. Philadelphia Indemnity investigated Parc Lorraine’s claim to determine if Parc Lorraine had suffered a loss under the policy. See doc. 54 at ¶¶ 5(e), 5(f). The parties agree that a covered loss occurred, see id. at ¶¶ 5(f); 5(h), but they “dispute the

amount of the loss caused by the storm,” id. at ¶ 5(i); see also doc. 57 at ¶¶ 28–29; doc. 61. Below, the Court finds facts regarding the policy and Philadelphia Indemnity’s consideration of Parc Lorraine’s claim. A. The policy The policy bore policy number PHPK1923583, doc. 57 at ¶ 1; doc. 61, and contained “various terms, conditions, provisions, limitations, and exclusions,” doc. 54 at ¶ 5(c). The parties agree that the following portions of the policy are relevant to Philadelphia Indemnity’s motion for partial summary judgment: PROPERTY COVERAGE FORM

Various provisions in this policy restrict coverage. Read this entire policy carefully to determine rights, duties and what is and is not covered.

Throughout this Coverage Form the words “you” and “your” refer to the Named Insured shown in the Declarations. The words “we”, “us” and “our” refer to the Company providing this insurance.

Other words and phrases that appear in quotation marks have special meaning. Refer to Section G., Definitions.

A. Coverage We will pay for direct physical “loss” to Covered Property caused by or resulting from any of the Covered Causes of Loss. *** E. Loss Conditions The following conditions apply in addition to the Common Policy Conditions and the Commercial Property Conditions: *** 4. Loss Payment a. In the event of “loss” to Covered Property covered by this Coverage form, at our option, we will either:

(1) Pay the value of lost or damaged property; (2) Pay the cost of repairing or replacing the lost or damaged property; (3) Take all or any part of the property at an agreed or appraised value; or (4) Repair, rebuild or replace the property with other property of like kind and quality. ***

7. Valuation

We will determine the value of Covered Property in the event of “loss” as follows:

a. At replacement cost (without deduction for depreciation) as of the time of “loss”, except as provided in b., c., d., e., f., g., and h. below.

(1) We will not pay more for “loss” on a replacement cost basis than the least of:

(a) The Limit of Insurance applicable to the lost or damaged property;

(b) The cost to replace the lost or damaged property with other property:

(i) Of comparable material and quality; and

(ii) Used for the same purpose; or

(c) The amount you actually spend that is necessary to repair or replace the lost or damaged property. *** *** (2) We will not pay on a replacement cost basis for any “loss”:

(a) Until the lost or damaged property is actually repaired or replaced; and

(b) Unless the repairs or replacement are made as soon as reasonably possible after the “loss”. If the repairs or replacement are not made as soon as reasonably possible after the “loss”, the value of the property will be actual cash value. ***

G. Definitions *** 7. “Loss” means accidental loss or damage. ***

***

CAUSES OF LOSS FORM

Words and phrases that appear in quotation marks have special meaning. Refer to Section F., Definitions.

A. Covered Causes of Loss

Covered Causes of Loss means Risks of Direct Physical Loss unless the “loss” is:

1. Excluded in Section B., Exclusions; or
2. Limited in Section C., Limitations;

that follow.

B. Exclusions ***

2. We will not pay for “loss” caused by or resulting from any of the following: ***

d. (1) Wear and tear;

(2) Rust, corrosion, fungus, decay, deterioration, spoilage, contamination, hidden or latent defect or any quality in property that causes it to damage or destroy itself; ***

3. We will not pay for “loss” caused by or resulting from any of the following. But if “loss” by a Covered Cause of Loss results, we will pay for that resulting “loss.” *** c. Faulty, inadequate, or defective: *** (2) Design, specifications, workmanship, repair, construction, renovation, remodeling, grading, compaction; (3) Materials used in repair, construction, renovation or remodeling; or (4) Maintenance;

Of part or all of any property on or off the described premises. ***

THIS ENDORSEMENT CHANGES THE POLICY. PLEASE READ IT CAREFULLY.

WINDSTORM OR HAIL PERCENTAGE DEDUCTIBLE

This endorsement modifies coverage provided under the following:

Property Coverage Form

The Windstorm or Hail Deductible, as shown in the Schedule, applies to direct physical “loss” to Covered Property, caused by or resulting from Windstorm or Hail, regardless of any other cause or event that contributes concurrently or in any sequence to the “loss” or damage. If “loss” from a covered weather condition other than Windstorm or Hail occurs, and that “loss” would not have occurred but for the Windstorm or Hail such “loss” shall be considered to be caused by Windstorm or Hail and therefore part of the Windstorm or Hail occurrence.

With respect to Covered Property at a location identified in the Schedule, no other deductible applies to Windstorm or Hail.

The Windstorm or Hail Deductible applies whenever there is an occurrence of Windstorm or Hail.

Windstorm or Hail Deductible Clause

A. All Policies

1. A deductible is calculated separately for and applies separately to:

a. Each building, if two or more buildings sustain “loss”. b. The building and to personal Property in that building, if both sustain “loss”.

c. Personal property at each building, if personal property at two or more buildings sustains “loss”.

d. Personal Property in the open.

2. We will not pay for “loss” until the amount of “loss” exceeds the applicable Deductible. We will then pay the amount of “loss” in excess of that Deductible up to the applicable Limit of Insurance, after any reduction required by any of the following:

a. Coinsurance Condition

b. Agreed Value Option Coverage

c. Reporting Endorsement

*** B.

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Parc Lorraine Condominium Association V. Philadelphia Indemnity Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parc-lorraine-condominium-association-v-philadelphia-indemnity-insurance-moed-2025.