Pham v. American Family Connect Property and Casualty Insurance Company

CourtDistrict Court, W.D. Washington
DecidedFebruary 7, 2025
Docket2:24-cv-01781
StatusUnknown

This text of Pham v. American Family Connect Property and Casualty Insurance Company (Pham v. American Family Connect Property and Casualty Insurance Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pham v. American Family Connect Property and Casualty Insurance Company, (W.D. Wash. 2025).

Opinion

5 UNITED STATES DISTRICT COURT 6 FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7

8 KHOA PHAM, et al., CASE NO. 2:24-cv-01781-RSL 9 Plaintiffs, v. 10

11 AMERICAN FAMILY CONNECT ORDER DENYING DEFENDANTS’ MOTION TO DISMISS AND/OR PROPERTY AND CASUALTY 12 INSURANCE COMPANY, F SO TAR T A E MM EO NR TE DEFINITE 13 Defendant. 14 15 This matter comes before the Court on defendant’s “Motion to Dismiss and for a 16 More Definite Statement.” Dkt. # 7. Having reviewed the motion and the remainder of the 17 18 record, the Court finds as follows: 19 BACKGROUND 20 Plaintiffs allege that they were insured by defendant American Family Connect 21 Property and Casualty Insurance Company when thieves broke into their home and stole 22 23 over $171,000 worth of collectibles, including limited edition designer bags, watches, 24 sunglasses, wallets, and shoes. The policy afforded $204,100 in “Personal Property 25 (Replacement Cost)” coverage. Plaintiffs further allege that they reported the theft to the 26 ORDER DENYING DEFENDANTS’ MOTION TO DISMISS 1 police, itemized the lost property, and filed a claim with their insurer, submitting all 2 receipts, confirmation orders, and pictures. On September 11, 2024, defendant offered 3 $29,181.35 to settle the claim, reducing the documented value of certain claimed items and 4 5 rejecting claims for items for which there was no legible receipt even if there were pictures 6 or other evidence supporting the claim. Plaintiffs rejected the offer and have not been able 7 to get their insurer to reevaluate the claim. 8 Plaintiffs, who are proceeding pro se, filed this lawsuit in King County Superior 9 10 Court on October 9, 2024. The complaint consists of a three-page letter and more than fifty 11 pages of documents related to the insurance policy and claim documentation. Plaintiffs 12 seek to compel payment of the replacement costs promised in the policy. Defendant timely 13 removed to federal court and filed this motion to dismiss the next day. Although plaintiffs 14 15 have not filed an opposition memorandum, they have submitted their discovery responses, 16 including a police report related to the burglary and receipts for and photos of the missing 17 items. 18 DISCUSSION 19 A. Motion to Dismiss 20 21 The question for the Court on a motion to dismiss under Rule 12(b)(6) is whether 22 the facts alleged in the complaint sufficiently state a “plausible” ground for relief. Bell Atl. 23 Corp. v. Twombly, 550 U.S. 544, 570 (2007). The Court must “accept factual allegations in 24 the complaint as true and construe the pleadings in the light most favorable to the 25 26 nonmoving party.” Manzarek v. St. Paul Fire & Marine Ins. Co., 519 F.3d 1025, 1031 (9th ORDER DENYING DEFENDANTS’ MOTION TO DISMISS 1 Cir. 2008) (citation omitted). The Court’s review is generally limited to the contents of the 2 complaint. Campanelli v. Bockrath, 100 F.3d 1476, 1479 (9th Cir. 1996). “We are not, 3 however, required to accept as true allegations that contradict exhibits attached to the 4 5 Complaint or matters properly subject to judicial notice, or allegations that are merely 6 conclusory, unwarranted deductions of fact, or unreasonable inferences.” Daniels-Hall v. 7 Nat’l Educ. Ass’n, 629 F.3d 992, 998 (9th Cir. 2010). 8 To survive a motion to dismiss under Rule 12(b)(6), a complaint must allege 9 “enough facts to state a claim to relief that is plausible on its face.” 10 []Twombly, 550 U.S. [at 570]. A plausible claim includes “factual content that allows the court to draw the reasonable inference that the defendant is 11 liable for the misconduct alleged.” U.S. v. Corinthian Colls., 655 F.3d 984, 12 991 (9th Cir. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). 13 Under the pleading standards of Rule 8(a)(2), a party must make a “short and plain statement of the claim showing that the pleader is entitled to relief.” 14 Fed. R. Civ. P. 8(a)(2). . . . A complaint “that offers ‘labels and conclusions’ 15 or ‘a formulaic recitation of the elements of a cause of action will not do.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). Thus, 16 “conclusory allegations of law and unwarranted inferences are insufficient to 17 defeat a motion to dismiss.” Adams v. Johnson, 355 F.3d 1179, 1183 (9th 18 Cir. 2004).

19 Benavidez v. Cty. of San Diego, 993 F.3d 1134, 1144–45 (9th Cir. 2021). If the complaint 20 fails to state a cognizable legal theory or fails to provide sufficient facts to support a claim, 21 22 dismissal is appropriate. Shroyer v. New Cingular Wireless Servs., Inc., 622 F.3d 1035, 23 1041 (9th Cir. 2010). 24 Defendant asserts that the complaint fails to “sufficiently allege facts that would 25 give fair notice [of the claim] and enable American Family to defend itself effectively.” 26 ORDER DENYING DEFENDANTS’ MOTION TO DISMISS 1 Dkt. # 7 at 4. In particular, defendant argues that plaintiffs have failed to allege facts which 2 could support a cause of action because (a) they acknowledge that defendant did not 3 unreasonably deny the claim and, in fact, extended coverage, (b) they have not identified 4 5 any law or regulation that was broken, and (c) they have not alleged a cognizable injury. 6 It is a longstanding rule in federal court that “[a] pro se complaint must be ‘liberally 7 construed,’ since ‘a pro se complaint, however inartfully pleaded, must be held to less 8 stringent standards than formal pleadings drafted by lawyers.’” Entler v. Gregoire, 872 9 10 F.3d 1031, 1038 (9th Cir. 2017) (quoting Erickson v. Pardus, 551 U.S. 89, 94 (2007), 11 which in turn quoted Estelle v. Gamble, 429 U.S. 97, 106 (1976)). Federal Rule of Civil 12 Procedure 8(a)(2) requires only “a short and plain statement of the claim showing that the 13 pleader is entitled to relief.” While a plaintiff must plead facts sufficient to show 14 15 entitlement to some relief in a court of law, he or she need not specify any particular cause 16 of action or statutory violation in order to survive a motion to dismiss. In Alvarez v. Hill, 17 518 F.3d 1152 (9th Cir.2008), for example, a prisoner sued prison officials alleging that 18 they substantially burdened his exercise of religion. The district court considered the 19 prisoner’s claim under the Free Exercise Clause of the First Amendment and granted 20 21 summary judgment in favor of the prison officials. The Ninth Circuit found, however, that 22 where the facts alleged gave defendants fair notice of a claim under the Religious Land 23 Use and Institutionalized Persons Act (“RLUIPA”), the district court should have 24 considered that independent statutory claim before granting summary judgment. 518 F.3d 25 26 at 1157. ORDER DENYING DEFENDANTS’ MOTION TO DISMISS 1 [Defendants’] argument that [plaintiff’s] complaint failed to “state a claim” 2 under RLUIPA because he did not cite the statute misapprehends the function of pleadings in federal practice.

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Pham v. American Family Connect Property and Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pham-v-american-family-connect-property-and-casualty-insurance-company-wawd-2025.