Pashkovsky v. GEICO Choice Insurance Company

CourtDistrict Court, E.D. Washington
DecidedDecember 28, 2020
Docket2:20-cv-00376
StatusUnknown

This text of Pashkovsky v. GEICO Choice Insurance Company (Pashkovsky v. GEICO Choice Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pashkovsky v. GEICO Choice Insurance Company, (E.D. Wash. 2020).

Opinion

1 EASTERN DISTRICT OF WASHINGTON 2 Dec 28, 2020 3 SEAN F. MCAVOY, CLERK 4 5 6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF WASHINGTON 8 9 TIMOTHY PASHKOVSKY, an No. 2:20-CV-00376-SAB 10 individual, 11 Plaintiff, ORDER RE: PLAINTIFF’S 12 v. MOTION FOR REMAND AND 13 GEICO CHOICE INSURANCE FOR ATTORNEY’S FEES 14 COMPANY, a foreign insurance company, 15 Defendant. 16 17 Before the Court is Plaintiff’s Motion to Remand and Case to State Court 18 and Motion for Attorney’s Fees, ECF No. 2. In addition, filed the day before the 19 remand motion was noted for hearing, Defendant filed a Sur-reply and Motion to 20 Strike Plaintiff’s late-filed reply in support of his motion, ECF No. 9. Plaintiff in 21 turn filed a Motion to Accept Late Reply Brief, ECF No. 10. The motions were all 22 considered without oral argument. Plaintiff is represented by Ronald Unger, and 23 Defendant is represented by Erin Thenell and Rory Leid. 24 Plaintiff requests the Court remand this matter to Grant County Superior 25 Court because Defendant’s removal was untimely under 28 U.S.C. § 1446. 26 Defendant argues that removal was proper because, according to Defendant, it was 27 not until the filing of the Second Amended Complaint in state court that Plaintiff 28 properly alleged claims giving rise to an amount in controversy in excess of 1 $75,000. For the reasons discussed below, the motion to remand is granted and the 2 motion for attorney’s fees is denied. The motion to strike and the motion to accept 3 late reply brief are denied as moot. 4 Factual Background and Procedural History 5 This case arises out of an insurance coverage dispute. Plaintiff alleges he 6 was seriously and permanently injured when a pickup truck driven by his father hit 7 him and pinned him against another truck. Plaintiff alleged that Geico had covered 8 his father with a $25,000 liability policy, plus an additional $25,000 in 9 underinsured motorist coverage. Plaintiff alleges he sent a demand letter to Geico 10 in August 2019, offering to settle the case for the policy limits, but Geico did not 11 respond. 12 Plaintiff then served a complaint on Geico on February 28, 2020, and that 13 complaint was filed on March 5, 2020 in Grant County Superior Court. Plaintiff 14 alleged that Geico failed to conduct a reasonable investigation and had taken 15 untenable positions that there was no liability coverage and no UIM coverage. He 16 further alleged that Geico was negligent, breached its contract, acted in bad faith, 17 and violated the Washington Insurance Fair Conduct Act (IFCA) and numerous 18 provisions of the Washington Administrative Code. Plaintiff alleged he was 19 entitled to attorney’s fees, judgment in excess of the policy limits, and treble 20 damages under IFCA. However, the IFCA claim was procedurally defective 21 because Plaintiff failed to serve written notice of the basis of the claim 20 days 22 prior to filing the action in accordance with Wash. Rev. Code § 48.30.015(8)(a). At 23 some point that is not clear from the record, but sometime after the filing of the 24 original complaint, Geico paid out the $25,000 policy limits to Plaintiff, but had 25 not paid out the UIM benefits. See ECF No. 2-1. 26 On May 6, 2020, Geico requested an itemization of Plaintiff’s attorney’s 27 fees in an attempt to resolve the claims. See ECF No. 2-3. The next day, Plaintiff’s 28 counsel provided the itemization. The email also notified Geico’s counsel that the 1 attorney’s fees already totaled $131,832. See ECF Nos. 2-4, 2-5. Geico’s attorney 2 responded the same day, confirming receipt. See ECF No. 2-6. 3 On May 11, 2020, Plaintiff filed his First Amended Complaint. The FAC 4 omitted the IFCA claim due to the procedural defect discussed above, but 5 otherwise raised the same claims as the original complaint. In addition, the FAC 6 added a Consumer Protection Act claim against Geico. The FAC also requested 7 judgment be entered for the entire amount of damages suffered even if in excess of 8 the $25,000 UIM policy limit, reasonable attorney’s fees, and treble damages. See 9 ECF No. 2-7. 10 On June 12, 2020, with newly-retained counsel, Geico wrote Plaintiff, 11 asserting for the first time that Geico was denying UIM coverage on the ground 12 that Plaintiff’s father allegedly committed fraud. See ECF No. 2-9. The same day, 13 Plaintiff sent a response letter denying the fraud allegations and advising that the 14 value of Plaintiff’s claim had increased to $137,907. See ECF No. 2-4, 2-5. 15 On July 23, 2020, Plaintiff served written notice on Geico, providing Geico 16 the basis for asserting IFCA violations as required by Wash. Rev. Code § 17 48.30.015(8)(a). See ECF No. 2-10. He also sent a demand letter outlining his 18 injuries and hospital bills and requested damages in excess of $900,000. See ECF 19 No. 2-11. Plaintiff then filed its Second Amended Complaint—the operative 20 Complaint—on October 1, 2020, alleging all causes of action in the FAC, plus the 21 IFCA claim. Geico removed the SAC to federal court on October 14, 2020 on the 22 basis of diversity jurisdiction. ECF No. 1. 23 Legal Standard 24 1. Removal 25 A civil action brought in a state court which could have originally been filed 26 in federal court may be removed by the defendant to the court for the district 27 embracing the state court. 28 U.S.C. § 1441(a). There is a strong presumption 28 against removal jurisdiction; the removing party always bears the burden of 1 establishing that removal is proper. Gaus v. Miller, 980 F.2d 564, 566 (9th Cir. 2 1992). Conclusory allegations will not suffice to overcome the traditional 3 presumption against removal jurisdiction. Rodgers v. Central Locating Serv., Ltd., 4 412 F. Supp. 2d 1171, 1178 (W.D. Wash. 2006). The notice of removal must be 5 filed within thirty days after receipt of the removable complaint, through service or 6 otherwise. 28 U.S.C. § 1446(b)(1). If the original pleading is not removable, a 7 notice of removal may be filed within thirty days after receipt of a copy of an 8 amended pleading, motion, order, or other paper from which it may first be 9 ascertained that the case is removable. 28 U.S.C. § 1446(b)(3). 10 For purposes of the second thirty-day period for removal, an “other paper” 11 does not include any paper received before the initial pleading. Carvalho v. 12 Equifax Info. Servs., 629 F.3d 876, 885-86 (9th Cir. 2010). Because some 13 pleadings may be “indeterminate” as to whether the face of the complaint 14 establishes grounds for removal, the time for removal is not triggered until the 15 defendant receives an amended or further pleading that “affirmatively reveals” the 16 case is removable. Kuxhausen v. BMW Fin. Servs. NA LLC, 707 F.3d 1136, 1139 17 (9th Cir. 2013) (finding that demand letter sent to defendant before the filing of the 18 initial complaint could not establish removability).

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Bluebook (online)
Pashkovsky v. GEICO Choice Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pashkovsky-v-geico-choice-insurance-company-waed-2020.