Renia B. Hudson v. Aig National Insurance Company

CourtLouisiana Court of Appeal
DecidedJune 2, 2010
DocketCA-0010-0063
StatusUnknown

This text of Renia B. Hudson v. Aig National Insurance Company (Renia B. Hudson v. Aig National Insurance Company) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Renia B. Hudson v. Aig National Insurance Company, (La. Ct. App. 2010).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

10-63

RENIA B. HUDSON

VERSUS

AIG NATIONAL INSURANCE

COMPANY, ET AL.

**********

APPEAL FROM THE TWELFTH JUDICIAL DISTRICT COURT PARISH OF AVOYELLES, NO. 2009-2986-B HONORABLE WILLIAM J. BENNETT, DISTRICT JUDGE

JOHN D. SAUNDERS JUDGE

Court composed of John D. Saunders, Jimmie C. Peters, and Elizabeth A. Pickett, Judges.

AFFIRMED.

Daniel G. Brenner Bolen, Parker, Brenner & Lee, Ltd. P. O. Box 11590 Alexandria, LA 71315-1590 (318) 445-8236 Counsel for Defendant Appellant: AIG National Insurance Co. Jerold Edward Knoll Jr. Esq. Attorney at Law P.O. Box 426 Marksville, LA 71351 (318) 253-6200 Counsel for Plaintiff Appellee: Renia B. Hudson

Mary Helen Johnson Johnson Law Firm, LLC P. O. Box 468 Marksville, LA 71351 (318) 253-0935 Counsel for Plaintiff Appellee: Renia B. Hudson SAUNDERS, Judge.

This case involves an automobile accident where the insured filed suit against

her insurer under her uninsured/underinsured policy not only for the balance of her

policy, but also for penalties that were eventually awarded under La.R.S. 22:1973.

The trial court found that the insurer had acted arbitrarily, capriciously, and without

probably cause in denying the insured’s claim. As such, under La.R.S.

22:1973(B)(5), the trial court awarded the insured an amount double her damages as

a penalty to the insurer for its actions.

The insurer filed this appeal, alleging four assignments of error. We find no

credence in any of these assignments and, therefore, affirm the trial court. Further,

we assess all costs of this appeal to the insurer.

FACTS AND PROCEDURAL HISTORY:

This matter arises out of an automobile accident that occurred on March 20,

2008, involving Renia B. Hudson (Hudson), an AIG National Insurance Company

(AIG) insured, operating a 2004 Mazda Miata and Kasarah Sayer, who was driving

a 1994 GMC pick-up truck. The pick-up truck was owned by Timmy Sayer and

insured by State Farm Mutual Insurance Company (State Farm). The accident

occurred when Hudson was traveling on East Tunica Drive in Marksville, Louisiana,

and the Sayer vehicle pulled out of a gas station, striking Hudson’s vehicle broadside.

The accident occurred solely as a result of the fault of Kasarah Sayer.

The State Farm policy provided a $10,000.00/$20,000.00 liability limit.

Hudson filed a claim with State Farm on that policy and eventually signed a release

in favor of State Farm, Timmy Sayer, and Kasarah Sayer in exchange for the policy

limit of $10,000.00.

At the time of the accident, Hudson had a policy of uninsured/underinsured motorist (UM) insurance coverage issued by AIG for a limit of $25,000.00. On

December 9, 2008, Hudson sent a demand letter to AIG for that limit. Attached to the

demand letter was Hudson’s medical profile, a certificate of coverage from State

Farm stating that the limits on Sayer’s policy of insurance were “10/20/25,” an

affidavit of coverage from Timmy Sayer stating that he had “no other liability

insurance . . . which would provide insurance benefits to [Hudson] for damages

sustained as a result of the collision on 03-20-08,” and a release executed by Hudson

in favor of Timmy Sayer, Kasarah Sayer, and State Farm in exchange for the policy

limits of ten thousand dollars.

Hudson’s medical profile included diagnostic tests taken of her cervical spine

at three different time frames following three different automobile accidents. The

first was taken in 2000, the second in 2005, and the third following the pertinent

accident, in 2008. The objective findings of those tests were that following the 2005

accident, Hudson showed no abnormalities related to her cervical spine, whereas,

after the 2008 accident, she had disc herniations at C4-5 and C5-6 and a disc bulge

at C3-4.

AIG refused to pay under the policy, claiming that it first needed to receive a

recorded statement from Hudson. Suit was filed against AIG on January 9, 2009,

alleging that Hudson was entitled to not only her damages, but also to penalties from

AIG under La.R.S. 22:1220 and 22:658.1

Thereafter, Hudson’s deposition was taken by AIG on May 14, 2009. On May

21, 2009, AIG made an unconditional tender of $11,744.00. Hudson rejected the

tender, and AIG placed those funds in the registry of the court.

1 Louisiana Revised Statutes 22:658 and 22:1220 are currently cited as La.R.S. 22:1892 and 22:1973 respectively.

2 A bench trial was held on July 19, 2009. The trial court issued reasons for

ruling and judgment on September 15, 2009. In its judgment, the trial court awarded

Hudson $25,000.00 from AIG under the terms of the UM policy. Further, the trial

court awarded Hudson $50,000.00 in penalties under La.R.S. 22:1973(B)(5) due to

its finding that Hudson was an extremely credible witness, that AIG’s adjuster, Jeff

Chighizola, testified in a very coy and evasive manner, and that AIG had acted in an

arbitrary and capricious manner without just cause. AIG has appealed this judgment,

alleging the following four assignments of error:

ASSIGNMENTS OF ERROR:

1. The trial court committed manifest error in failing to grant AIG’s motion for involuntary dismissal where no prima facie case was proven by Hudson to satisfy the strict and narrowly construed requirements of the penal statutes La.R.S. 22:1892 and La.R.S. 22:1973.

2. The trial court erred by granting penalties under La.R.S. 22:1973 where Hudson filed suit alleging bad faith prior to any actual occurrence of what Hudson alleges to be “bad faith” under the statute.

3. The trial court committed manifest error in granting La.R.S. 22:1973 damages and penalties where the evidence does not support a finding of insurer bad faith.

4. The trial court erred in calculating the La.R.S. 22:1973 and other “damages” allegedly incurred by AIG’s alleged bad faith actions.

ASSIGNMENT OF ERROR NUMBER ONE:

In its first assignment of error, AIG contends that the trial court committed

manifest error in failing to grant its motion for involuntary dismissal where no prima

facie case was proven by Hudson to satisfy the strict and narrowly construed

requirements of the penal statutes La.R.S. 22:1892 and La.R.S. 22:1973. For the

following reason, we find no basis for this assignment.

Louisiana Code of Civil Procedure Article 1672(B) (emphasis added) states:

3 In an action tried by the court without a jury, after the plaintiff has completed the presentation of his evidence, any party, without waiving his right to offer evidence in the event the motion is not granted, may move for a dismissal of the action as to him on the ground that upon the facts and law, the plaintiff has shown no right to relief. The court may then determine the facts and render judgment against the plaintiff and in favor of the moving party or may decline to render any judgment until the close of all the evidence.

A trial court’s determination on a party’s motion granting an involuntary

dismissal is reviewed using the manifest error standard of review. Gauthier v. City

of New Iberia, 06-341 (La.App. 3 Cir. 9/27/06), 940 So.2d 915. Thus, for this court

to reverse a trial court’s granting of a motion for involuntary dismissal, we must find

that there lacks a factual basis for its determination, i.e., that the determination is

manifestly erroneous, clearly wrong, or unreasonable. See Stobart v. State, through

DOTD, 617 So.2d 880 (La.1993).

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