Peacock Automotive LLC v. Granite State Insurance Company

CourtCourt of Appeals for the Fourth Circuit
DecidedFebruary 16, 2024
Docket22-1283
StatusUnpublished

This text of Peacock Automotive LLC v. Granite State Insurance Company (Peacock Automotive LLC v. Granite State Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peacock Automotive LLC v. Granite State Insurance Company, (4th Cir. 2024).

Opinion

USCA4 Appeal: 22-1283 Doc: 41 Filed: 02/16/2024 Pg: 1 of 13

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-1283

PEACOCK AUTOMOTIVE, LLC,

Plaintiff - Appellant,

v.

GRANITE STATE INSURANCE COMPANY,

Defendant - Appellee.

Appeal from the United States District Court for the District of South Carolina, at Beaufort. Bruce H. Hendricks, District Judge. (9:20-cv-01303-BHH)

Submitted: October 10, 2023 Decided: February 16, 2024

Before GREGORY and AGEE, Circuit Judges, and Robert S. BALLOU, United States District Judge for the Western District of Virginia, sitting by designation.

Affirmed by unpublished opinion. Judge Gregory wrote the opinion, in which Judge Agee and Judge Ballou joined.

ON BRIEF: Bradford N. Martin, Laura W.H. Teer, BRADFORD NEAL MARTIN & ASSOCIATES, PA, Greenville, South Carolina, for Appellant. C. Mitchell Brown, Blake T. Williams, NELSON MULLINS RILEY & SCARBOROUGH LLP, Columbia, South Carolina; J.C. Nicholson, III, COLLINS AND LACY, Columbia, South Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 22-1283 Doc: 41 Filed: 02/16/2024 Pg: 2 of 13

GREGORY, Circuit Judge:

This case arises from an insurance dispute for business income losses allegedly

sustained by Peacock Automotive LLC (“Peacock”) as a result of the mandatory

evacuation of certain South Carolina counties due to an incoming hurricane. The district

court denied Peacock’s motion for partial summary judgment and granted summary

judgment to defendant Granite State Insurance Company (“Granite”). Peacock appealed.

Finding no error by the district court, we affirm.

I.

Peacock, a Florida limited liability company, operates several businesses in Jasper

County, South Carolina. To insure its commercial properties, Peacock purchased an

insurance policy (“the Policy”) from Appellee Granite. That policy had a coverage period

of January 1, 2019, to January 1, 2020. The policy provision relevant to this case (the

“Civil Authority Provision”) provided:

We shall pay for the actual loss of your business income and extra expense caused by or resulting from action by a civil authority that prohibits access to the premises described in the Declarations due to direct physical loss of or damage to property, other than at the premises described in the Declarations, caused by or resulting from a covered cause of loss.

J.A. 32 (emphasis added).

On August 22, 2019, Hurricane Dorian began forming in the Atlantic Ocean. South

Carolina Governor Henry McMaster issued several executive orders in anticipation of

Dorian’s impact. The first two orders declared a state of emergency and permitted the

governor to activate the South Carolina Emergency Operation Plan to protect citizens

2 USCA4 Appeal: 22-1283 Doc: 41 Filed: 02/16/2024 Pg: 3 of 13

against Dorian’s effects. On September 1, 2019, Governor McMaster issued three more

executive orders, including Executive Order No. 2019-28. That order, relevant to this case,

mandated the evacuation of several coastal counties, including Jasper County, effective at

noon the following day. The Executive Order explained that the severity of the hurricane

“represent[ed] a significant threat to the State of South Carolina” and thus “require[d] the

State to take timely precautions to protect and preserve property, critical infrastructure,

communities, and the general safety and welfare of the people of this State.” J.A. 128

(emphasis added). Notably, the Executive Order referenced no existing property damage

caused by Dorian as a basis for the directive.

Peacock sought to comply with the Order and shut down business operations on

September 2. Three days later, Peacock filed a claim under the Policy for “Business

Interruption loss due to the passing of Hurricane Dorian” at several of its locations. On

October 1, 2019, a third-party claims administrator for Granite informed Peacock that it

was investigating the matter while reserving its rights not to pay the claim, depending on

the outcome of the investigation. In that reservation letter, the administrator explained that

the insurer had concerns that some of the damages claimed might have resulted from non-

covered or excluded causes of loss. The letter explained that the administrator would

conduct a review of all claimed damages and evaluate Peacock’s eligibility for coverage

under the policy, including under the policy’s Civil Authority Provision.

The third-party administrator officially denied Peacock’s claim on December 9,

2019. According to the denial letter, the administrator determined that since Peacock did

not sustain damage at any of its covered locations, its closure was not covered under the

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policy. The correspondence further explained that “the evacuation order pre-ceded the

storm and states . . . for evacuation due to the ‘potential impact of Hurricane Dorian.’”

Granite therefore determined that “the evacuation was not declared due to direct physical

loss or damage to any property, but in anticipation of the storm to protect the residents of

the county.” J.A. 140.

On January 30, 2020, Peacock’s counsel—seemingly unaware of the denial letter

—responded to the reservation letter, demanding coverage under the Policy. In that

correspondence, Peacock asserted that the evacuation order “was made as a result of the

severe property loss evidenced in the Bahamas as Hurricane Dorian continued to threaten

the east coast of the United States.” J.A. 143. Peacock attached a letter from Kim Stenson,

Director of the South Carolina Emergency Management Division. In that letter, Stenson

explained that the governor’s evacuation order was issued because of the “severe property

loss evidenced in the Bahamas . . .[,] the significant potential threat to South Carolina, and

based on the recommendations of local, state and federal officials[.]” J.A. 144. The

Stenson letter was dated 127 days after Governor McMaster issued his order and almost a

month after Granite denied Peacock’s claim.

When Peacock did not receive a satisfactory response, it filed a state court action on

March 4, 2020. In its complaint, Peacock alleged that Granite breached the Policy by

refusing to cover business income losses sustained due to the evacuation order. Peacock

asserted that the order was based on a significant threat of property damage in Jasper

County and maintained that Granite acted in bad faith when it refused to pay Peacock’s

claim. Granite removed the action to the U.S. District Court for the District of South

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Carolina based on diversity jurisdiction. After the parties engaged in discovery, Peacock

filed a motion for partial summary judgment and Granite filed a cross-motion for summary

judgment on both of Peacock’s claims.

The district court denied Peacock’s motion but granted Granite’s motion in its

entirety. According to the district court, there was no coverage under the Civil Authority

Provision because the Executive Order was not issued “due to” the property damage in the

Bahamas. The district court explained that, to trigger the Policy, an evacuation order must

be issued “because of” damage to property adjacent or within a certain proximity to covered

premises. J.A. 340–43.

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Peacock Automotive LLC v. Granite State Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peacock-automotive-llc-v-granite-state-insurance-company-ca4-2024.