Quillen v. State Farm Mutual Automobile Insurance Company

CourtSuperior Court of Delaware
DecidedFebruary 25, 2025
DocketS23C-10-030 RHR
StatusPublished

This text of Quillen v. State Farm Mutual Automobile Insurance Company (Quillen v. State Farm Mutual Automobile Insurance Company) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Quillen v. State Farm Mutual Automobile Insurance Company, (Del. Ct. App. 2025).

Opinion

SUPERIOR COURT OF THE STATE OF DELAWARE

ROBERT H. ROBINSON, JR. Sussex County Courthouse JUDGE 1 The Circle, Suite 2 Georgetown, DE 19947 Telephone: (302) 856-5264

Submitted: December 18, 2024 Decided: February 25, 2025

Edward C. Gill, Esq. Matthew E. O’Byrne, Esq. Stephen W. Welsh, Esq. Daniella C. Spitelli-Sarnecky, Esq. Alaina M. Chamberlain, Esq. Casarino Christman Shalk Ransom & Gill, Welsh & Chamberlain, P.A. Doss, P.A. 16 North Bedford Street 1000 N. West Street, Suite 1450 Georgetown, DE 19947 Wilmington, DE 19899 Attorneys for Plaintiff Charles Attorneys for Defendant State Farm Daniel Quillen Mutual Automobile Insurance Company

Re: Charles Daniel Quillen v. State Farm Mutual Automobile Insurance Company and Progressive Direct Insurance Company. C.A. No.: S23C-10-030 RHR

Dear Counsel:

This matter arose after Plaintiff Charles Daniel Quillen (“Quillen”) sustained

injuries in a car accident while riding as a passenger in a vehicle operated by Maria

Loa-Soto (“Loa-Soto”). Quillen settled his injury claim against Loa-Soto for the full

amount of her insurance policy’s limits through Defendant State Farm Mutual

Automobile Insurance Company (“State Farm”). Quillen brought this action to collect underinsured motorist (“UIM”) benefits from State Farm. State Farm has

moved for summary judgment.1 For the following reasons, State Farm’s motion for

summary judgment is GRANTED.

The burden of proof on a motion for summary judgment under Superior Court

Civil Rule 56 requires the moving party to demonstrate that there is “no genuine

issue as to any material fact, and that the moving party is entitled to judgment as a

matter of law.”2 If the burden is satisfied, the non-moving party must establish the

“existence of one or more issues of material fact.”3 “All facts and reasonable

inferences are considered in a light most favorable to the non-moving party.”4

Summary judgment may not be granted where there is a material fact in dispute or

where “it seems desirable to inquire thoroughly into [the facts] in order to clarify the

application of the law to the circumstances.”5

This matter hinges on Delaware’s choice of law rules, which, in this case,

impose the law of the state with the “most significant relationship to the occurrence

and the parties.”6 The parties disagree as to whether Delaware or Maryland’s policy

limit laws apply. Quillen’s action cannot survive summary judgment under

1 Defendant Progressive Direct Insurance Company was dismissed from this case by order dated August 5, 2024. 2 Super. Ct. Civ. R. 56(c). 3 Quality Elec. Co., Inc. v. E. States Const. Serv., Inc., 1995 WL 379125, at *3-4 (Del. 1995). 4 Nutt v. A.C. & S. Co., Inc., 517 A.2d 690, 692 (Del. Super. 1986) (citing Mechell v. Plamer, 343 A.2d 620, 621 (Del. 1975)). 5 Ebersole v. Lowengrub, 180 A.2d 467, 469-70 (Del. 1962). 6 Tiller v. Nationwide Mutual Insurance Company, 2007 WL 2199648, at *1 (Del. Super. 2007). 2 Maryland’s interpretation of its UIM laws. Under Maryland law, UIM limits are

offset by any award already paid to the plaintiff by the tortfeasor. Under Delaware

law, UIM limits are not offset by the previously recovered award. Quillen has already

recovered $30,000 for his injuries. Because State Farm’s UIM limit is $30,000,

Quillen would be unable to recover anything further under the policy if Maryland’s

offset rule applied.

It is uncontested that the insurance policy in question is a Maryland policy—

it was written and purchased in Maryland and expressly provides that it is controlled

by Maryland law. Further, at the time of the accident, the vehicle covered under the

policy was registered in Maryland and Loa-Soto was listed as a Maryland resident

under the policy. Tiller v. Nationwide Mutual Insurance Company informs this

matter, as it shares a nearly analogous set of facts.7 In Tiller, the plaintiffs were

Maryland residents seeking UIM payments after being injured in a car accident in

Delaware. This court determined that Maryland shared the most significant

relationship with the occurrence and the parties, reasoning that “[t]he parties are

from Maryland; the vehicles are registered in Maryland; the contract was purchased

and written in Maryland; the policy’s [UIM] coverage provision expressly states that

the policy is covered under Maryland law; and, the benefits will be paid in

7 Id. 3 Maryland.”8 The Tiller court noted that the only Delaware contacts were the location

of the accident itself and the plaintiff having received treatment in Delaware.9 The

only relevant distinctions between the instant case and Tiller are that the policyholder

gave a Delaware address to the police who responded to the accident, and the

plaintiff is a Delaware resident.

The parties’ place of residence is not determinative in this case. Quillen argues

that Tiller is not controlling because “Maryland’s only connection to the case is that

[Loa-Soto] was a former resident of the [s]tate and may or may not have informed

her insurance carrier of her relocation prior to the Delaware accident.”10 The former

argument overlooks important facts (e.g. the insurance policy was issued in

Maryland, where the car was registered) and the latter does not shield Quillen from

summary judgment. Loa-Soto’s apparent failure to inform State Farm of her new

Delaware address is understandable, but that fact does not outweigh the considerable

Maryland contacts in this case. It is worth noting that the Tiller court determined that

it was “readily apparent that Maryland [had] the most significant relationship to [the

Tillers’] claim.”11 This court is not persuaded that the parties’ residence alone could

have changed the outcome of Tiller. Likewise, Loa-Soto’s Delaware residence

8 Id. 9 Id. 10 D.I. 29, Pl’s. Ans. Br. Opp. Def. State Farm Mut. Auto. Ins. Co’s. Mot. Summ. J. at 9. 11 Tiller at *1 (emphasis added). 4 should not render an opposite ruling in an otherwise analogous case (in which she is

not a named party). To the extent that Loa-Soto’s residence does carry any weight,

it weighs in favor of summary judgment as Loa-Soto held herself out to be a

Maryland resident when she signed the contract, and State Farm was not on notice

of her new residence until this matter arose.12 If Loa-Soto had changed her address

to Delaware, State Farm was certainly not on notice of the change at the time of the

accident. In keeping with the Tiller decision, this court also finds that applying

Maryland law is consistent with the policyholder’s expectations.13 Loa-Soto’s policy,

like the Tillers’, “expressly calls for the offset against its limit” and for the

application of Maryland law through its nonduplication and choice of law provisions

respectively.14

“The flexibility of [the most significant relationship] doctrine requires that

each case be decided on its own facts.”15 In this case, the policyholder’s place of

residence carries less weight because she is not the plaintiff, and she was a Maryland

resident when she signed the contract and purchased the policy. Delaware courts will

give policyholders’ place of residence greater weight when doing so has serious

12 D.I. 33, Def. State Farm Mut. Auto. Ins. Co’s. Supp. App. Reply Br., Exhibit D at 2-3. 13 Tiller at *2.

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Related

Ebersole v. Lowengrub
180 A.2d 467 (Supreme Court of Delaware, 1962)
Nutt v. AC & S. CO., INC.
517 A.2d 690 (Superior Court of Delaware, 1986)
Mechell v. Palmer
343 A.2d 620 (Supreme Court of Delaware, 1975)
Travelers Indemnity Co. v. Lake
594 A.2d 38 (Supreme Court of Delaware, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
Quillen v. State Farm Mutual Automobile Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/quillen-v-state-farm-mutual-automobile-insurance-company-delsuperct-2025.