Parodi v. Liberty Mutual Fire Insurance Company

CourtDistrict Court, N.D. California
DecidedJune 6, 2023
Docket3:23-cv-01663
StatusUnknown

This text of Parodi v. Liberty Mutual Fire Insurance Company (Parodi v. Liberty Mutual Fire Insurance Company) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parodi v. Liberty Mutual Fire Insurance Company, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 KARIN PARODI, Case No. 23-cv-01663-JSC

8 Plaintiff, ORDER VACATING HEARING AND 9 v. GRANTING DEFENDANT’S MOTION TO STAY ACTION PENDING 10 LIBERTY MUTUAL INSURANCE ARBITRATION COMPANY, 11 Re: Dkt. No. 11 Defendant.

12 13 Plaintiff Karin Parodi alleges Defendant Liberty Mutual Insurance breached its contractual 14 obligations and the implied covenant of good faith and fair dealing while engaged in an arbitration 15 for insurance damages arising from a car accident. (Dkt. No. 1.) Defendant’s motion to compel 16 arbitration and dismiss or, alternatively, stay the action pending completion of the arbitration is 17 now pending before the Court. (Dkt. No. 11.) After carefully considering the parties’ written 18 submissions, the Court concludes that oral argument is unnecessary, see Civ. L.R. 7-1(b), and 19 grants Defendant’s motion and stays the case pending the completion of arbitration. 20 BACKGROUND 21 A. Complaint Allegations 22 Plaintiff is insured by Defendant under a written motor vehicle insurance policy. (Dkt. No. 23 1 ¶ 10.) 1 Plaintiff and an underinsured motorist were involved in a motor vehicle collision. (Id. ¶ 24 11.) Plaintiff received $100,000 from the driver’s liability insurance and later, pursuant to her 25 insurance policy with Defendant, submitted an uninsured motorist (“UIM”) claim to Defendant, 26 demanding an additional $150,000. (Id. ¶¶ 12-16.) Defendant responded it needed more 27 1 information and declined the demand. (Id. ¶¶ 17-18.) The policy requires unresolved claims 2 proceed through arbitration. (Dkt. No. 11-1 at 37.) In accordance with California Insurance Code 3 § 11580.2(f), the arbitration provision states: “If we and an ‘insured’ do not agree: (1) Whether 4 that person is legally entitled to recover damages under this Part; or (2) As to the amount of 5 damages; either party may make a written demand for arbitration.” (Id.) (cleaned up). 6 Following this policy language, Plaintiff demanded a UIM arbitration. (Dkt. No. 1 ¶ 21.) 7 The parties completed some informal discovery. (Id. ¶¶ 22, 25.) However, as discovery 8 continued, Plaintiff became increasingly displeased with Defendant’s handling of her claim. (Id. 9 ¶¶ 22, 25-28, 30-34.) Plaintiff alleges Defendant proceeded in bad faith during arbitration and 10 breached its contractual obligations to Plaintiff. Specifically, Plaintiff objects to Defendant’s 11 evasive tactics throughout the arbitration, such as delays and refusals in responding to discovery 12 requests. (Id. ¶¶ 33-34.) Plaintiff also makes more general allegations that investigations into her 13 claim have been mishandled. (Id.) 14 B. Procedural Background 15 Plaintiff filed this action in San Mateo County Superior Court. (Dkt. No. 1 at 6.) 16 Defendant then filed a notice of removal on diversity jurisdiction grounds. (Dkt. No. 1.) 17 Defendant filed the present motion to compel. (Dkt. No. 11.) 18 LEGAL STANDARD 19 The Court’s power to stay an action is discretionary and is “incidental to the power 20 inherent in every court to control the disposition of the causes on its docket with economy of time 21 and effort for itself, for counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 22 (1936). To determine whether a stay should be granted, the court considers the possible damage 23 which may result from the granting of a stay and the “hardship or inequity” which a party may 24 suffer in being required to go forward. Id. at 254-55. The court should evaluate the likelihood 25 that a stay will serve the interests of judicial economy. Lockyer v. Mirant Corp., 398 F.3d 1098, 26 1112 (9th Cir. 2005). Under the Federal Arbitration Act, “[i]f any suit or proceeding be brought in 27 any of the courts of the United States upon any issue referable to arbitration under an agreement in 1 issue involved in such suit or proceeding is referable to arbitration under such an agreement, shall 2 on application of one of the parties stay the trial of the action until such arbitration has been had in 3 accordance with the terms of the agreement . . . .” 9 U.S.C. § 3. “Where some issues are subject 4 to arbitration and others are not, the trial court has the discretion to stay the balance of the 5 proceedings pending arbitration.” Countrywide Home Loans v. Mortgage Guar. Ins. Co., No. 10- 6 CV-00233 JSW, 2011 WL 4948538, at *2 (N.D. Cal. Oct. 18, 2011) (citing Mediterranean Enter., 7 Inc. v. Ssangyong Corp., 708 F.2d 1458, 1465 (9th Cir. 1983)).2 The issues need not be identical 8 to empower a court to stay the proceedings in one suit. Landis, 299 U.S. at 254. 9 DISCUSSION 10 It is undisputed Plaintiff’s breach of contract claim must be resolved by arbitration. (Dkt. 11 No. 11 at 6; Dkt. No. 12 at 2.) Section 11580.2(f) of the California Insurance Code provides that 12 the determination as to “whether the insured shall be legally entitled to recover damages, and if so 13 entitled, the amount thereof, shall be made by agreement between the insured and the insurer or, in 14 the event of disagreement, by arbitration.” Cal. Ins. Code § 11580.2(f). Plaintiff’s insurance 15 policy includes an arbitration agreement pursuant to § 11580.2(f). (Dkt. No. 11-1 at 37.) Indeed, 16 Plaintiff agrees her breach of contract claim must be resolved in the arbitration currently 17 proceeding. (Dkt. No. 12 at 2.) 18 The only remaining issue is whether Plaintiff’s bad faith claim may proceed in this Court 19 while the breach of contract arbitration continues. The Landis factors favor staying the bad faith 20 claim pending the completion of the UIM arbitration. Landis, 299 U.S. at 254. 21 I. A Stay Will Serve the Interests of Judicial Economy. 22 Although the arbitration proceedings will not directly address the bad faith claim, the 23 arbitration’s result will impact the bad faith claim’s resolution in this court. 24

25 2 California Civil Code of Procedure § 1281.4 does not apply. First, it is a procedural law, and 26 questions of procedure in a federal diversity case are governed by federal law. See Cuprite Mine Partners LLC v. Anderson, 809 F.3d 548, 554 (9th Cir. 2015) (“Under the Erie doctrine, federal 27 courts sitting in diversity apply state substantive law and federal procedural rules.”). Second, and relatedly, its language governs only what California state courts must do. See, e.g., Thomas v. 1 Plaintiff contends Defendant failed to thoroughly and fairly investigate, process, and 2 evaluate Plaintiff’s UIM claim. (Dkt. No. 1 ¶¶ 22, 32.) The arbitration’s determination of the 3 breach of contract claim is relevant to whether Defendant mishandled Plaintiff’s claim. To 4 establish an insurer’s bad faith under California law, Plaintiff must show it “(1) withheld benefits 5 due under the policy, and (2) that such withholding was ‘unreasonable’ or ‘without proper cause.’” 6 Luu v. Allstate Ins. Co., No. 5:11-CV-01523 EJD, 2011 WL 3360040, at *2 (N.D. Cal. Aug. 2, 7 2011) (citing Major v. W. Home Ins. Co., 169 Cal. App. 4th 1197, 1209 (2009)). If the arbitrator 8 finds Plaintiff is owed compensation, Plaintiff’s allegations that Defendant unreasonably withheld 9 payment and failed to process the claim would be bolstered. See Thomas v. State Farm Mut. Auto. 10 Ins. Co., No. 15-CV-00509 CRB, 2015 WL 1544244, at *1 (N.D. Cal. Apr. 2, 2015) (citing 11 Morello v. Amco Ins. Co., No.

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Related

Landis v. North American Co.
299 U.S. 248 (Supreme Court, 1936)
Corral v. State Farm Mutual Automobile Insurance
92 Cal. App. 3d 1004 (California Court of Appeal, 1979)
Major v. Western Home Insurance
169 Cal. App. 4th 1197 (California Court of Appeal, 2009)
Lockyer v. Mirant Corp.
398 F.3d 1098 (Ninth Circuit, 2005)
Cuprite Mine Partners v. John Anderson
809 F.3d 548 (Ninth Circuit, 2015)
Holland v. Department of Motor Vehicles
92 Cal. App. 3d 25 (California Court of Appeal, 1979)

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Parodi v. Liberty Mutual Fire Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parodi-v-liberty-mutual-fire-insurance-company-cand-2023.