Regional Enterprises, Inc. v. Hartford Accident & Indemnity Co.

16 Va. Cir. 230, 1989 Va. Cir. LEXIS 92
CourtRichmond County Circuit Court
DecidedJune 27, 1989
DocketCase No. LL-2550-4
StatusPublished

This text of 16 Va. Cir. 230 (Regional Enterprises, Inc. v. Hartford Accident & Indemnity Co.) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Regional Enterprises, Inc. v. Hartford Accident & Indemnity Co., 16 Va. Cir. 230, 1989 Va. Cir. LEXIS 92 (Va. Super. Ct. 1989).

Opinion

By JUDGE RANDALL G. JOHNSON

This case involves a dispute arising out of an insurance policy issued to plaintiff, Regional Enterprises, Inc., by defendant, the Hartford Accident and Indemnity Company, Inc. After a jury returned a verdict for defendant, plaintiff moved for a directed verdict, for judgment notwithstanding the verdict, or for a new trial. Those motions were taken under advisement, and the parties were requested to file written memoranda in support of their positions, which memoranda have now been received. For the reasons which follow, plaintiff’s motions will be denied, and judgment will be entered in accordance with the jury’s verdict.

The insurance policy in dispute provided coverage for certain vehicles owned by the plaintiff. Among those vehicles was what is known as a "T-8 sugar trailer" which plaintiff used to transport high fructose corn syrup, also known as liquid sugar. Such trailers are actually little more than large, insulated, metal, hollowbore cylinders wrapped in aluminum and pulled by tractors. There is a manhole in the top of the trailer with a two-part hinged cover or lid with attached wing bolts to secure it. On September 20, 1986, plaintiff’s trailer was found [231]*231by plaintiff’s employees to be in a collapsed or "imploded" condition; that is, outside air pressure had caused the trailer to collapse inward, much like an aluminum soda can being crushed in someone’s hand.

The parties do not disagree on the physical cause of the trailer’s collapse. Specifically, the evidence showed that the interior of the trailer is cleaned by washing it with cold water and then steam-cleaning it. The trailer is then parked with the lid to the manhole open so that the trailer is allowed to vent; that is, the interior of the trailer is allowed to reach ambient temperature, or a temperature where the air pressure inside the trailer equals the air pressure outside the trailer. Such venting is crucial since if the steam inside the trailer is not allowed to escape through the manhole, condensation and a lowering of air pressure inside the trailer will occur. If the inside air pressure becomes too low, the outside air pressure will collapse or implode the trailer. The parties agree that this is what happened here. They disagree, however, on how the manhole became closed.

Plaintiff’s witnesses testified that on the day before the trailer was found collapsed, Charles Steward, one of plaintiff’s drivers, had driven the trailer for the purpose of transporting a load of liquid sugar. He returned to plaintiff’s terminal, steam-cleaned the trailer, and left it with the manhole open in front of plaintiff’s main business office next to a loading bay. He left plaintiff’s premises between 4:00 and 5:00 p.m. Another employee, Howard Irwin, who believes that he (Irwin) was the last person to leave plaintiff’s terminal that day, testified that when he left he saw steam coming out of the manhole, indicating that it was still open. When the trailer was found in its collapsed condition the next morning, it was in the same place it had been left the day before. The manhole, however, was closed. A police investigation, as well as plaintiff’s own investigation, failed to reveal who closed the manhole.1 It is interesting to note, however, that Charles Steward, the driver who washed and parked [232]*232the truck, ceased working for plaintiff two days after the incident and that changes were made in the washing procedure which were designed to prevent similar occurrences in the future.2

The Hartford policy insured plaintiff’s trailer against certain specified perils. At issue here is Hartford’s coverage against "mischief or vandalism." It is plaintiff’s position that the evidence mandates a finding that the trailer’s manhole was closed. through mischief or vandalism, and that the jury’s verdict must be set aside. Hartford, on the other hand, argues that the jury simply decided that plaintiff failed to carry its burden of showing that the incident was an act of mischief or vandalism, and that the verdict should stand.

The gravamen of plaintiff’s argument concerns the court’s refusal to give five instructions requested by plaintiff. Those instructions would have provided as follows:

PLAINTIFF’S INSTRUCTION A
To recover under the specified peril of "vandalism," plaintiff must prove by the greater weight of the evidence that:
(1) an intentional act was done by some known or unknown person,
(2) the act was done in conscious or intentional disregard of the rights of the plaintiff and the property damaged; and
(3) that the act was the proximate cause of damage to the trailer.
PLAINTIFF’S INSTRUCTION B
To recover under the specified peril of "mischief," plaintiff must prove by the greater weight of the evidence that:
[233]*233(1) an act was done by some known or unknown person;
(2) the act caused plaintiff harm, annoyance, trouble, or damage; and,
(3) that the act was the proximate cause of damage to the trailer.
In order to recover the plaintiff does not have to prove that the act of mischief was intentional or done out of spite or ill will.
PLAINTIFF’S INSTRUCTION C
Vandalism is not defined by the terms of the insurance contract which is the subject matter of this lawsuit. Therefore, it must be defined by its usual or common meaning. Thus, vandalism is usually and commonly defined as the destruction of property generally, and the act of destruction must be willful and malicious.
Malicious means that the act of destruction must have been intentional or in reckless and wanton disregard of the rights of others.
Legal malice need not amount to ill will, hatred, or vindictiveness of purpose but may consist of a wanton, conscious, or intentional disregard of the rights of another.
Malice may be inferred or presumed from the act of destruction itself.
PLAINTIFF’S INSTRUCTION D
Mischief is not defined by the terms of the insurance contract which is the subject matter of this lawsuit. Therefore, it must be defined by its usual or common meaning.
Mischief is usually or commonly defined as an action that causes harm, annoyance, trouble, or injury. It is further defined as trouble or vexation caused by human agency or by some living being, intentionally or not.
Malice is not an element of mischief.
[234]*234PLAINTIFF’S INSTRUCTION E

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Cite This Page — Counsel Stack

Bluebook (online)
16 Va. Cir. 230, 1989 Va. Cir. LEXIS 92, Counsel Stack Legal Research, https://law.counselstack.com/opinion/regional-enterprises-inc-v-hartford-accident-indemnity-co-vaccrichmondcty-1989.