QST v. National Union Fire Ins.

2002 DNH 105
CourtDistrict Court, D. New Hampshire
DecidedMay 28, 2002
DocketCV-98-572-M
StatusPublished

This text of 2002 DNH 105 (QST v. National Union Fire Ins.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
QST v. National Union Fire Ins., 2002 DNH 105 (D.N.H. 2002).

Opinion

QST v. National Union Fire Ins. CV-98-572-M 05/28/02 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

QST Environmental, Inc. f/k/a Environmental Science _____ & Engineering, Inc., Plaintiff

v. Civil No. 98-572-M Opinion No. 2002 DNH 105 National Union Fire Insurance Company _____ of Pittsburgh, PA; and United National Insurance Company, Defendants

O R D E R

The plaintiff, QST Environmental, Inc. ("ESE"), brings

breach of contract, including breach of the duty of good faith

and fair dealing, claims against National Union Fire Insurance

Company ("National") and United National Insurance Company

("UNIC"). ESE's claims are based on its status as an "additional

insured" on policies issued by National and UNIC to OHM

Remediation Services ("OHMRS") and arise from the settlement of

an underlying tort suit. ESE and both defendants move for

summary judgment. Background

EnergyNorth Natural Gas, Inc., entered into a contract with

ESE related to hazardous waste remediation at its property in

Concord, New Hampshire. ESE in turn contracted with OHMRS to

perform related work at the site. ESE's contract with OHMRS

included an indemnification provision as well as a requirement

that ESE be named as an additional insured on OHMRS's relevant

insurance policies. OHMRS was insured under a commercial general

liability policy issued by National and an umbrella liability

policy issued by UNIC. ESE was in fact included as an additional

insured on both policies.

In May of 1994, Thomas Shoemaker, an employee of OHMRS, was

severely injured while working on the remediation project at the

EnergyNorth site. His parents brought suit on his behalf,

alleging claims against EnergyNorth, ESE, and OHMRS' parent

company (Shoemaker's employer, OHMRS was immune under the

worker's compensation b a r ) . Shoemaker claimed ESE was negligent

in supervising OHMRS, committed engineering malpractice, breached

a non-delegable duty, and was vicariously liable for the

negligence of OHMRS.

2 National agreed to defend ESE in the Shoemaker action,

subject to a reservation of rights. The parties engaged in

private mediation in August of 1998. ESE did not participate in

the settlement negotiations in its own right, but only through

the insurance carriers.

In September of 1998, National tendered its policy limit of

$1,000,000.00 to UNIC, and UNIC took over the defense of the

case. ESE declined to contribute its own funds to settle all of

Shoemaker's claims. Late in September, Shoemaker settled his

claims against defendants, except ESE, for $7,900,000.00. The

settling parties executed a release. The claims against ESE

based on theories of vicarious liability (Counts III and IV in

the Shoemaker complaint) were resolved and ESE was released from

liability as to those claims.

Shoemaker continued to pursue his distinct claims against

ESE for negligence (Count I) and engineering malpractice (Count

II). UNIC refused to provide ESE with a defense or coverage as

to those claims. ESE and Shoemaker later settled those remaining

claims. ESE, itself, paid Shoemaker $225,000 to settle the

3 engineering malpractice claim. ESE's commercial general

liability insurer, Illinois National Insurance Company, paid

Shoemaker $825,000 to settle the discrete negligence claim

against ESE.

ESE subsequently sued OHMRS, asserting claims for indemnity

and breach of the duty of good faith and fair dealing. In the

release executed as part of the settlement with Shoemaker,

however, ESE relinquished any claims for indemnification against

OHMRS. Accordingly, ESE amended its complaint, withdrawing the

indemnification claim against OHMRS. ESE also sued UNIC and

National, alleging breach of contract and breach of the duty of

good faith and fair dealing. The two suits were consolidated

into the present action. In the course of the litigation, ESE's

claim against OHMRS, OHMRS's counterclaim against ESE, and UNIC's

counterclaim against ESE were dismissed. Only ESE's claims

against UNIC and National remain.

Discussion

ESE's claims against UNIC and National allege breach of

contract and breach of the duty of good faith and fair dealing.

4 ESE says that because it was an additional insured on the UNIC

and National Insurance policies issued to OHMRS, UNIC and

National owed ESE a defense and indemnification with regard to

Shoemakers' distinct negligence claim against ESE.1 ESE also

claims that UNIC and National breached the duty of good faith and

fair dealing by favoring OHMRS, and prejudicing ESE's ability to

settle the claims against it that were not covered by UNIC and

National. ESE moves for summary judgment on liability only.

UNIC and National move for summary judgment in their favor on all

of ESE's claims.

UNIC and National raise a preliminary issue regarding ESE's

standing to bring these claims because ESE's own liability

insurer, Illinois National Insurance Company, actually paid the

settlement amount to resolve Shoemaker's negligence claim against

ESE. In addition, Illinois National paid ESE's defense costs, to

the extent those costs were not covered by National and UNIC. By

seeking summary judgment on liability only, ESE may be trying to

1 ESE concedes that neither the UNIC policy nor the National policy provided coverage for the engineering malpractice claim.

5 avoid the question of loss. But ESE's loss in this context is

not a question of damages, but one of standing.2

"Every action shall be prosecuted in the name of the real

party in interest." Fed. R. Civ. P. 17(a). "the general rule in

federal court is that if an insurer has paid the entire claim of

its insured, the insurer is the real party in interest under

Federal Rule of Civil Procedure 1 7 (a) and must sue in its own

name."3 Krueger v. Cartwright, 996 F.2d 928, 931-32 (7th Cir.

1993)(citing United States v. Aetna Casualty & Surety Co., 338

U.S. 366, 380-81 (1949)). When an insurer pays only part of the

loss and the insured pays part, both the insurer and the insured

must bring their claims in the litigation in their own names.

Aetna. 338 U.S. at 381-82.

2 The collateral source rule, relied on by ESE to avoid the standing issue, applies only to preserve an award of damages and does not affect a party's standing to litigate a claim. See Concord Hosp. v. N.H. Med. Malpractice Joint Underwriting Ass'n, 142 N.H. 59, 61 (1997); Cvr v. J . I . Case C o .. 139 N.H. 193, 196 (1994) .

3 Similarly, under New Hampshire law, subrogation rights may arise from contract provisions or from the equitable subrogation doctrine. See DeLellis v. Burke. 134 N.H. 607, 610 (1991); Dimick v. Lewis, 127 N.H. 141, 144 (1985).

6 In this case, it is undisputed that Illinois National

provided the defense to Shoemaker's independent negligence claim

against ESE (to the extent the defense was not paid for by UNIC

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Related

United States v. Aetna Casualty & Surety Co.
338 U.S. 366 (Supreme Court, 1950)
Dimick v. Lewis
497 A.2d 1221 (Supreme Court of New Hampshire, 1985)
Centronics Corp. v. Genicom Corp.
562 A.2d 187 (Supreme Court of New Hampshire, 1989)
DeLellis v. Burke
598 A.2d 203 (Supreme Court of New Hampshire, 1991)
Cyr v. J.I. Case Co.
652 A.2d 685 (Supreme Court of New Hampshire, 1994)
Ahrendt v. Granite Bank
740 A.2d 1058 (Supreme Court of New Hampshire, 1999)

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