Phillip P. Crace, M.D. v. Jorge Campo

CourtCourt of Appeals of Kentucky
DecidedMarch 14, 2024
Docket2022 CA 001182
StatusUnknown

This text of Phillip P. Crace, M.D. v. Jorge Campo (Phillip P. Crace, M.D. v. Jorge Campo) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phillip P. Crace, M.D. v. Jorge Campo, (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 15, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1182-MR

PHILLIP P. CRACE, M.D. APPELLANT

APPEAL FROM FLOYD CIRCUIT COURT v. HONORABLE EDDY COLEMAN, JUDGE ACTION NO. 11-CI-00439

JORGE CAMPO AND PROASSURANCE CASUALTY COMPANY APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, CALDWELL, AND LAMBERT, JUDGES.

CALDWELL, JUDGE: Dr. Phillip Crace appeals from a decision of the Floyd

Circuit Court granting summary judgment to Appellees Jorge Campo and

ProAssurance Company on Crace’s bad faith claims. We affirm.

RELEVANT FACTUAL AND PROCEDURAL HISTORY

The record in this case is so voluminous that it fills ten large boxes.

Such an enormous record is inherently unwieldy, but this case presents a special challenge because there are multiple boxes containing thousands of pages of

unpaginated, unbound materials. The lack of pagination makes it extremely

difficult for us to locate specific items in the vast record. We recognize the

difficulty of collating such a mammoth record. Nonetheless, we emphasize the

requirement of RAP1 26(B)(1) to bind and securely arrange the entire written

record into volumes containing not more than 150 pages each.

In the interests of judicial economy, we shall relate only the truly

necessary underlying facts and procedural history. Similarly, we have examined

the parties’ lengthy briefs but shall discuss only the arguments strictly necessary to

resolve the issues before us. Any argument presented in the briefs which is not

discussed in this Opinion is redundant, irrelevant, or otherwise without merit.

This bad faith case arose from a malpractice case in which Crace, a

physician, was a defendant. Crace’s malpractice insurer was ProAssurance, and

Campo was the adjuster assigned to that case. The malpractice claim against Crace

was settled for $1 million, Crace’s policy limits, roughly fourteen months after it

was filed. Crace contends he sent a letter to ProAssurance demanding the

malpractice claim be settled roughly six months before the settlement actually

occurred. However, Crace did not direct the letter to Campo or any other

ProAssurance decisionmaker. ProAssurance disputes having received the letter.

1 Kentucky Rules of Appellate Procedure.

-2- Crace filed a first-party bad faith claim against ProAssurance and

Campo, arguing, for example, that the settlement was belated, and he was harmed

because ProAssurance did not allocate a portion of the settlement to his then-

current or former medical practice. The trial court granted summary judgment to

ProAssurance and Campo, after which Crace filed this appeal.

ANALYSIS

A. Standards of Review

We have succinctly set forth the standards governing summary

judgments as follows:

Summary judgment is proper where there exists no genuine issue of material fact and movant is entitled to judgment as a matter of law. All facts and all inferences drawn from those facts are viewed in a light most favorable to the nonmoving party. Because summary judgment involves only questions of law and the existence of disputed material issues of fact, an appellate court does not defer to a circuit court’s decision and reviews the case de novo.

Messer v. Universal Underwriters Insurance Company, 598 S.W.3d 578, 583-84

(Ky. App. 2019) (citations omitted).

As to bad faith, generally, an insurer “is required to deal with the

insured or third-party claimant in good faith.” Belt v. Cincinnati Insurance

Company, 664 S.W.3d 524, 531 (Ky. 2022). Of course, an insurer may “challenge

a claim and litigate it if the claim is debatable on the law or facts.” Id. at 535

-3- (quotation marks and citations omitted). A viable bad faith claim is based not only

on delay in resolving an underlying claim; instead, actionable bad faith is premised

upon a showing of “intentional misconduct or reckless disregard of the rights of an

insured . . . .” Id. at 531 (internal quotation marks and citation omitted). In short,

“an action for bad faith . . . requires something more than mere negligence. The

term itself implies some intentional wrongful conduct . . . . Mere errors in

judgment should not be sufficient to establish bad faith.” Blue Cross and Blue

Shield of Kentucky, Inc. v. Whitaker, 687 S.W.2d 557, 559 (Ky. App. 1985).

A viable bad faith claim must satisfy three elements:

(1) the insurer must be obligated to pay the claim under the terms of the policy; (2) the insurer must lack a reasonable basis in law or fact for denying the claim; and (3) it must be shown that the insurer either knew there was no reasonable basis for denying the claim or acted with reckless disregard for whether such a basis existed.

Belt, 664 S.W.3d at 532 (citations omitted).

B. ProAssurance’s Business Model Is Irrelevant

We begin our analysis by quickly deeming immaterial Crace’s

extended argument regarding what he perceives as ProAssurance’s general

business practice of seeking to maximize profits by delaying resolution of claims

made against its insureds. Of course, ProAssurance did ultimately pay Crace’s

policy limit to resolve the malpractice claim, which undermines his argument.

-4- Moreover, an insurer generally may “challenge a claim and litigate it

if the claim is debatable on the law or facts.” Id. at 535 (internal quotation marks

and citations omitted). Crace’s malpractice liability was debatable as he denied

wrongdoing in his deposition and experts consulted by ProAssurance agreed. In

any event, the question here is whether ProAssurance committed misconduct

defending the malpractice claim, not whether its alleged business model is morally

optimal. After all, it is beyond reasonable dispute that the goal of most businesses

is to maximize profits. In sum, we restrict our analysis to the acts taken by

ProAssurance in this case, not its alleged overall business methodology.

C. Crace Failed to Plead a Breach of Fiduciary Duty Claim

We also reject Crace’s argument that the trial court erred by not

discussing a breach of fiduciary duty claim. Simply put, there was no such claim

to discuss because Crace did not adequately plead one. Neither Crace’s initial nor

amended intervening complaints uses the term fiduciary. Instead, the complaints

assert ProAssurance had – and breached – a duty of good faith and fair dealing and

generally placed its interests above Crace’s. Such language is insufficient.

There was a contractual relationship between Crace and

ProAssurance, and “[w]ithin every contract, there is an implied covenant of good

faith and fair dealing, and contracts impose on the parties a duty to do everything

necessary to carry them out.” Bailey v. Kentucky Lottery Corporation, 542 S.W.3d

-5- 305, 309 (Ky. App. 2018). A fiduciary duty is “more than the generalized business

obligation of good faith and fair dealing.” Ballard v. 1400 Willow Council of Co-

Owners, Inc., 430 S.W.3d 229, 242 (Ky. 2013) (citation omitted). Therefore, a

breach of fiduciary duty claim cannot properly lie on an allegation that a defendant

violated the universal contractual obligations of good faith and fair dealing.

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