Rancosky, M. v. Washington National

CourtSuperior Court of Pennsylvania
DecidedDecember 16, 2015
Docket1282 WDA 2014
StatusPublished

This text of Rancosky, M. v. Washington National (Rancosky, M. v. Washington National) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rancosky, M. v. Washington National, (Pa. Ct. App. 2015).

Opinion

J-A19039-15

2015 PA Super 264

MATTHEW RANCOSKY, ADMINISTRATOR IN THE SUPERIOR COURT OF DBN OF THE ESTATE OF LEANN PENNSYLVANIA RANCOSKY, AND MATTHEW RANCOSKY, EXECUTOR OF THE ESTATE OF MARTIN L. RANCOSKY,

Appellants

v.

WASHINGTON NATIONAL INSURANCE COMPANY, AS SUCCESSOR BY MERGER TO CONSECO HEALTH INSURANCE COMPANY, FORMERLY KNOWN AS CAPITAL AMERICAN LIFE INSURANCE COMPANY,

Appellee No. 1282 WDA 2014

Appeal from the Judgment Entered August 1, 2014 In the Court of Common Pleas of Washington County Civil Division at No(s): 2008-11797

BEFORE: BENDER, P.J.E., JENKINS, J., and MUSMANNO, J.

CONCURRING AND DISSENTING OPINION BY JENKINS, J.:

FILED: December 16, 2015

I concur with the majority’s decision to affirm the entry of summary

judgment in favor of Conseco1 on Martin’s claims. I respectfully dissent from

the majority’s decision to vacate the judgment on LeAnn’s claims and

____________________________________________

1 I use the same shorthand references to the parties as in the majority opinion.

1 J-A19039-15

remand for a new trial on LeAnn’s claim for bad faith under 42 Pa.C.S. §

8371. In my view, LeAnn’s bad faith claim is time-barred under

Pennsylvania’s two-year statute of limitations for bad faith, 42 Pa.C.S. §

5524.

The majority contends in footnote 30 of its opinion that Conseco

waived the statute of limitations issue by failing to raise it in post-verdict

motions. I am constrained to disagree.

At the close of evidence during trial, Conseco moved for a directed

verdict on LeAnn’s bad faith claim based on the statute of limitations. N.T.,

6/27/14, at 168-72. The trial court took the motion for directed verdict

under advisement. Id. at 172. Subsequent to trial, the trial court entered a

decision in favor of Conseco on the merits, finding that LeAnn failed to

present clear and convincing evidence of bad faith. Verdict, 7/3/14, at 1-2.

The trial court did not address the statute of limitations issue.

As the verdict winner, Conseco could not file post-verdict motions

objecting to the trial court’s failure to decide the statute of limitations issue.

DeFazio v. Labe, 507 A.2d 410, 414 (Pa.Super.1986) (“[because]

judgment n.o.v. is the directing of a verdict in favor of the losing party,

despite a verdict to the contrary … we must therefore agree with the lower

court that appellees, as verdict winners, lack standing to move for a

-2- J-A19039-15

judgment n.o.v.”) (emphasis in original).2 Because Conseco lacked

standing, as the verdict winner, to file post-verdict motions in the trial court

seeking judgment n.o.v. on the statute of limitations, Conseco did not waive

its statute of limitations argument in this Court.

In addition, the evidence demonstrates, as a matter of law, that

LeAnn’s claim is time-barred. This Court has the authority to affirm the trial

court on the basis of the statute of limitations, even though the trial court

decided the case on another ground. “[W]e are not bound by the rationale

of the trial court and may affirm on any basis.” Richmond v. McHale, 35

A.3d 779, 786 n. 2 (Pa.Super.2012).

Under Pennsylvania law, a bad faith action under 42 Pa.C.S. § 8371 is

subject to a two-year statute of limitations. Ash v. Continental Ins. Co.,

932 A.2d 877, 885 (Pa.2007). In general, a claim accrues when the plaintiff

is harmed. Adamski v. Allstate Ins. Co., 738 A.2d 1033, 1042-43

(Pa.Super.1999). In other words, “a statute of limitations begins to run as

soon as the right to institute suit arises. This is true regardless of whether

the full extent of harm is known when the action arises.” Id. “Whether a

2 The Supreme Court granted allocatur in DeFazio but split 3-3 concerning whether verdict winners lack standing to move for judgment n.o.v. DeFazio v. Labe, 543 A.2d 540, 541-45 (Pa.1988). Thus, the Superior Court’s decision in DeFazio was affirmed on this issue, Id., and it remains good law today. See Marks v. Nationwide Ins. Co., 762 A.2d 1098, 1101 (Pa.Super.2000) (decision of Superior Court remains precedential until it has been overturned by Supreme Court).

-3- J-A19039-15

complaint is timely filed within the limitations period is a matter of law for

the court to determine.” Crouse v. Cyclops Indus., 745 A.2d 606, 611

(Pa.2000). “Once a cause of action has accrued and the prescribed

statutory period has run, an injured party is barred from bringing his cause

of action.” Fine v. Checcio, 870 A.2d 850, 857 (Pa.2005).

Pennsylvania courts have held that a bad faith claim under 42 Pa.C.S.

§ 8371 is deemed to have accrued at the point the claim for insurance

benefits is first denied. See, e.g., Ash v. Continental Ins. Co., 861 A.2d

979, 984 (Pa.Super.2004) (two-year limitation period began running at

initial denial of coverage for damage to insured’s property under first-party

fire policy), aff’d, 932 A.2d 877 (Pa.2007); Adamski, 738 A.2d at 1040

(limitation period under section 8371 began to run upon first occurrence of

refusal to pay). Thus, the statute of limitations begins running when the

insurer sends a letter denying a claim, even where the insurer later agrees

to re-evaluate a decision to deny benefits at the request of the insured.

See, e.g., Jones v. Harleysville Mut. Ins. Co., 900 A.2d 855, 858-59 (Pa.

Super.2006) (statute of limitations began running when insurer first issued

letter denying claim for property damage under fire policy; rejecting

argument that statute of limitations did not begin running until after insurer

conducted additional investigation and sent another letter reaffirming

previous decision to deny coverage); see also Cozzone v. AX4 Equitable

Life Ins. Soc., 858 F.Supp.2d 452, 459 (M.D.Pa.2012) (“an insurance

company’s willingness to reconsider its denial does not toll the statute of

-4- J-A19039-15

limitations, as the limitations period runs from the time when Plaintiff’s claim

was first denied”).3 The bad faith statute also begins running when the

insurer sends a letter terminating the policy for failure to make timely

premium payments. See Bariski v. Reassure America Life Ins. Co., 834

F.Supp.2d 233, 237 (M.D. Pa. 2011). Nor can the plaintiff extend the

limitations period by arguing that the insurer’s bad faith conduct was

continuing, because the plaintiff is not entitled to “separate initial and

continuing refusals to provide coverage into distinct acts of bad faith.”

Adamski, 738 A.2d at 1042; see also CRS Auto Parts, Inc. v. Nat’l

Grange Mut. Ins. Co., 645 F.Supp.2d 354, 365 (E.D.Pa. 2009) (“where an

insurer clearly and unequivocally puts an insured on notice that he or she

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Related

Ash v. Continental Insurance
932 A.2d 877 (Supreme Court of Pennsylvania, 2007)
DeFazio v. Labe
543 A.2d 540 (Supreme Court of Pennsylvania, 1988)
Crouse v. Cyclops Industries
745 A.2d 606 (Supreme Court of Pennsylvania, 2000)
Marks v. Nationwide Insurance Co.
762 A.2d 1098 (Superior Court of Pennsylvania, 2000)
Fine v. Checcio
870 A.2d 850 (Supreme Court of Pennsylvania, 2005)
Dietz v. Chase Home Finance, LLC
41 A.3d 882 (Superior Court of Pennsylvania, 2012)
Adamski v. Allstate Insurance Co.
738 A.2d 1033 (Superior Court of Pennsylvania, 1999)
DeFazio v. Labe
507 A.2d 410 (Supreme Court of Pennsylvania, 1986)
Ash v. Continental Insurance Co.
861 A.2d 979 (Superior Court of Pennsylvania, 2004)
Jones v. Harleysville Mutual Insurance
900 A.2d 855 (Superior Court of Pennsylvania, 2006)
CRS Auto Parts, Inc. v. National Grange Mutual Insurance
645 F. Supp. 2d 354 (E.D. Pennsylvania, 2009)
Rancosky v. Washington National Insurance
130 A.3d 79 (Superior Court of Pennsylvania, 2015)
Richmond v. McHale
35 A.3d 779 (Superior Court of Pennsylvania, 2012)
Bariski v. Reassure America Life Insurance
834 F. Supp. 2d 233 (M.D. Pennsylvania, 2011)

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