Park v. State Farm Mutual Automobile Insurance Company

CourtDistrict Court, E.D. New York
DecidedJanuary 27, 2022
Docket2:20-cv-01982
StatusUnknown

This text of Park v. State Farm Mutual Automobile Insurance Company (Park v. State Farm Mutual Automobile Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Park v. State Farm Mutual Automobile Insurance Company, (E.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -------------------------------------------------------------X For Online Publication Only SOON PARK and JAE LEE,

Plaintiffs, MEMORANDUM AND ORDER -against- 20-CV-1982 (JMA) (SIL)

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY and ERICA HROMAS,

Defendants. -------------------------------------------------------------X AZRACK, United States District Judge: Plaintiffs Soo Park and Jae Lee (“Plaintiffs”) commenced this action against State Farm Mutual Automobile Insurance Company and Erica Hromas (“Defendants”) on April 30, 2020 alleging: (1) breach of contract based on lost wages, physical damages coverage, underinsured or uninsured motorist (“UM/UIM”) benefits, and medical bills; (2) fraudulent transfer of insurance policy benefits; (3) breach of the implied covenant of good faith and fair dealing and unfair trade practices; and (4) economic coercion, harassment, and emotional distress, all related to an automobile accident that Plaintiff Lee was involved in while driving a vehicle owned by Plaintiff Park. (ECF No. 1.) Defendants filed a motion to dismiss pursuant Federal Rules of Civil Procedure 12(b)(5) for insufficient service of process and 12(b)(6) for failure to state a cause of action. Defendants’ 12(b)(6) motion sought to dismiss all claims, except one portion of the breach of contract claim related to medical bills. (ECF No. 14.) On May 25, 2021, the Court referred the motion to dismiss to Magistrate Judge Steven I. Locke for a Report and Recommendation (“R&R”). (Electronic Order, 5/25/2021.) Judge Locke issued an R&R dated October 20, 2021, which recommends that Defendants’ Rule 12(b)(5) motion be denied and their Rule 12(b)(6) motion granted in its entirety. The R&R recommends that Plaintiffs’ only remaining claim (breach of contract based on medical bills for $320.22.) be dismissed without prejudice. (ECF No. 22.) Objections must be filed within 14 days of receipt of the R&R. See 28 U.S.C. § 636(b)(1) (“Within fourteen days after being served with a copy, any party may serve and file written objections to such proposed findings and recommendations as provided by rules of court.”); Fed.

R. Civ. P. 72 (“Within 14 days after being served with a copy of the recommended disposition, a party may serve and file specific written objections to the proposed findings and recommendations.”) Accordingly, objections were due on November 3, 2021. Plaintiffs did not file objections to the R&R until November 4, 2021. (ECF No. 23.) Therefore, Plaintiffs’ objections are denied as untimely. See Lugo v. Berryhill, 390 F. Supp. 3d 453, 461 (S.D.N.Y. 2019) (denying objections that were filed 20 days after the R&R was issued as untimely) Even assuming arguendo Plaintiffs’ objections were timely, the Court finds that Plaintiffs’ objections should be denied. After conducting a review of the full record (including the motion papers, R&R, and objections) and applicable law, the Court adopts Judge Locke’s R&R as the

opinion of the Court, with the minor exception that this Court: (1) dismisses Plaintiffs’ breach of contract claim premised on UM/UIM benefits without prejudice; and (2) does not dismiss Plaintiffs’ remaining breach of contract claim based on medical bills for $320.22. In reviewing a magistrate judge’s report and recommendation, a court must “make a de novo determination of those portions of the report or . . . recommendations to which objection[s] [are] made.” 28 U.S.C. § 636(b)(1)(C); -se -e -al-so- -B-ro-w-n- -v-. -E-b-er-t, No. 5-CV-5579, 2006 WL 3851152, at *2 (S.D.N.Y. Dec. 29, 2006). The Court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(1)(C). Those portions of a report and recommendation to which there is no specific reasoned objection are reviewed for clear error. See Pall Corp. v. Entegris, Inc., 249 F.R.D. 48, 51 (E.D.N.Y. 2008). Applying clear error review to the aspects of the R&R for which no objections have been filed, the Court adopts Judge Locke’s recommendations except that the Court does not sua sponte dismiss Plaintiffs’ breach of contract claim based on medical bills. I next address the portions of the R&R to which Plaintiffs have objected. For Plaintiffs’

objections, I have undertaken a de novo review of the record, the R&R, the objections, and the opposition. Plaintiffs argue that the individual claims against Defendant Hromas should not be dismissed because she is personally liable; Plaintiffs’ claims for car repairs, rental car expenses, and loss of use of the car are timely; the lost wage claim should not be dismissed; and attorney’s fees and punitive damages should be awarded. These objections reiterate Plaintiffs’ previous arguments and were already addressed by the R&R. Having considered the full record, the Court denies those objections for the reasons articulated in Judge Locke’s R&R. Plaintiffs also argue that their breach of contract claim based on State Farm’s alleged failure to reimburse them for UM/UIM benefits should not be dismissed and include new allegations

regarding this claim. (ECF No. 23 at 4-5.) Judge Locke recommended that this claim should be dismissed with prejudice because Plaintiffs failed to plead sufficient facts to state a cause of action. (R&R at 26-27.) As the R&R explains, under New York law certain conditions precedent must be pled in order to state a cause of action for a UM/UIM claim: the bodily injury limits of liability coverage of a tortfeasor’s vehicle are less than the bodily injury limits of coverage of the insured, and “the limits of liability of all bodily injury liability bonds or insurance policies applicable at the time of the accident have been exhausted by payment of judgments or settlements.” Garcia v. State Farm Ins. Co., 232 A.D.2d 488, 489 (2d Dep’t 1996); see Maurizzio v. Lumbermens Mut. Cas. Co., 73 N.Y.2d 951, 953 (1989); N.Y. Insur. Law § 3420(f)(2)(A). Judge Locke found that the complaint failed to allege “(i) the bodily injury limits of liability coverage of Mora’s vehicle [the other vehicle involved in the accident] were less than the bodily injury limits available under the Policy; (ii) that Plaintiffs have exhausted those limits by payment of judgments or settlements; (iii) that Mora’s policy limits were insufficient to compensate Lee for her injuries; and (iv) that Plaintiffs have filed a claim with State Farm for UM or UIM benefits.” (R&R at 27.) Therefore,

Judge Locke found that Plaintiffs failed to allege the conditions precedent to bring suit, and because Plaintiffs did not seek leave to amend, that the claim be dismissed with prejudice. (-Id-.) In support of their argument, Plaintiffs attach to their objections: (1) an accident reconstruction report; and (2) a letter dated November 2, 2021 from GEICO, Mora’s insurance company, offering $25,000 as full and final settlement of Plaintiff Lee’s bodily injury claim with a draft release, dated November 2, 2021. (ECF Nos. 23-1, 23-2.) Plaintiffs argue in their objections that the $25,000 is Mora’s policy limit and that Plaintiff Lee’s injuries exceed that limit, and therefore their claim should not be dismissed. (Objections at 5.) However, rather than bolster Plaintiffs’ allegations, the additional allegations only highlight that Plaintiffs’ claim does not meet the necessary

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Related

Maurizzio v. Lumbermens Mutual Casualty Co.
538 N.E.2d 334 (New York Court of Appeals, 1989)
Garcia v. State Farm Insurance
232 A.D.2d 488 (Appellate Division of the Supreme Court of New York, 1996)
Lugo v. Berryhill
390 F. Supp. 3d 453 (S.D. Illinois, 2019)
Pall Corp. v. Entegris, Inc.
249 F.R.D. 48 (E.D. New York, 2008)

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Bluebook (online)
Park v. State Farm Mutual Automobile Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/park-v-state-farm-mutual-automobile-insurance-company-nyed-2022.