Richard and Cynthia McCarver v. Richard L. Bogan and Government Employees Insurance Company

CourtCourt of Appeals of Mississippi
DecidedJanuary 14, 2020
DocketNO. 2018-CA-01619-COA
StatusPublished

This text of Richard and Cynthia McCarver v. Richard L. Bogan and Government Employees Insurance Company (Richard and Cynthia McCarver v. Richard L. Bogan and Government Employees Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard and Cynthia McCarver v. Richard L. Bogan and Government Employees Insurance Company, (Mich. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2018-CA-01619-COA

RICHARD AND CYNTHIA McCARVER APPELLANTS

v.

RICHARD L. BOGAN AND GOVERNMENT APPELLEES EMPLOYEES INSURANCE COMPANY

DATE OF JUDGMENT: 10/17/2018 TRIAL JUDGE: HON. ANDREW K. HOWORTH COURT FROM WHICH APPEALED: MARSHALL COUNTY CIRCUIT COURT ATTORNEYS FOR APPELLANTS: JOHN THOMAS LAMAR III TAYLOR ALLISON HECK ATTORNEYS FOR APPELLEES: WILTON V. BYARS III DAVID EARL ROZIER JR. JENESSA JO CARTER HICKS MARK CHRISTOPHER WOODS NATURE OF THE CASE: CIVIL - PERSONAL INJURY DISPOSITION: REVERSED AND REMANDED - 01/14/2020 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

GREENLEE, J., FOR THE COURT:

¶1. Richard McCarver (McCarver) was injured in an accident when another vehicle

driven by Richard Bogan (Bogan) crossed the center line. McCarver and his wife, Cynthia,1

filed suit in the Marshall County Circuit Court against Bogan. In the complaint, the

McCarvers alleged that Bogan was liable for unpaid property damage and bodily injury

1 Throughout this opinion “McCarver” refers to Richard McCarver. The “McCarvers” references both Richard and Cynthia McCarver. “Bogan” refers to Richard Bogan. claims arising out of the accident. The McCarvers later amended their complaint to include

their insurer, GEICO, as a defendant under an underinsured-motorist-coverage claim. After

three months of discovery, Bogan filed a motion for summary judgment under Rule 56 of the

Mississippi Rules of Civil Procedure, stating McCarver had accepted a settlement check from

Bogan’s insurer that read “full and final settlement” of “any and all” claims “for bodily

injury.” GEICO joined his motion and supplemented a response. After a hearing on the

motion, the circuit court granted Bogan’s summary judgment motion and entered judgment,

ruling that an accord and satisfaction had occurred. On appeal, the McCarvers argue the

circuit court erred in granting summary judgment. Finding error, we reverse and remand this

matter for further proceedings.

FACTS AND PROCEDURAL HISTORY

¶2. On August 22, 2014, Bogan was involved in a head-on collision with McCarver when

Bogan crossed into McCarver’s traffic lane. Bogan was insured by Allstate. McCarver’s

insurance was with GEICO. Under the GEICO policy, McCarver had uninsured and

underinsured motorist coverage. Because of it, GEICO paid McCarver the base value of

McCarver’s vehicle.2 McCarver called Allstate, Bogan’s insurer, claiming to their adjustor

that he had not been reimbursed in full for his property damage. Specifically, McCarver

sought payments for loss of rebate, the increased down payment on his new vehicle, and

2 The record fails to indicate the exact date GEICO paid McCarver for the value of his truck. However, Allstate’s financial log shows that Allstate reimbursed GEICO, in whole or in part, on Feburary 2, 2015, in the amount of $24,786.00.

2 specific items he had added to his vehicle prior to the accident, such as window tint and a

toolbox. The Allstate adjustor informed McCarver that Allstate was not responsible for the

rebate loss or the additional down payment.

¶3. Following their conversation, the adjustor visited McCarver at his body shop on or

around October 8, 2014. There, the adjustor issued McCarver a check in the amount of

$2,160.00 that included a notation in the upper left-hand corner that stated “full and final

settlement” of “any and all” claims “for bodily injury.” A copy of the check is pictured in

the appendix below. McCarver cashed the check five days later on October 14, 2014. The

parties dispute what was said before and at the time the check was issued to McCarver. The

McCarvers claim the $2,160.00 check was the result of “an agreement regarding the

additional items McCarver had purchased for his truck [prior to the accident].” Bogan

contests that the check was negotiated “to settle McCarver[’]s bodily injury claim[s].”

¶4. However, Allstate’s financial log evinces six additional checks that Allstate issued to

various payees for McCarver’s benefit because of the automobile accident. The second,

third, fourth, and fifth checks were issued on October 9, 2014. The second check paid

McCarver in the amount of $214.00. The parties fail to mention this check in their briefs.

According to the financial log, however, the transactional reason for the check was “property

damage liability.” The third, fourth, and fifth checks were issued to various medical

3 providers to pay for McCarver’s immediate medical expenses.3 Allstate reimbursed GEICO

by the sixth check in February 2015 in the amount of $24,786.00 for damage to McCarver’s

vehicle. The seventh (and final) check from Allstate was issued on August 12, 2015, to

Methodist Hospital for $11,737.40 to pay for McCarver’s additional medical bills.

¶5. On April 26, 2017, the McCarvers filed suit in Marshall County Circuit Court against

Bogan for unpaid property damage and bodily injury claims. According to the McCarvers’

complaint, McCarver was driving north on Highway 309 in Marshall County, and Bogan was

driving south. McCarver claimed that without warning “[Bogan] recklessly crossed over into

[McCarver’s] lane of travel and struck [McCarver’s] vehicle head on.” The McCarvers

alleged that Bogan’s negligence caused McCarver property damage, personal injury, and pain

and suffering; and Cynthia alleged loss of consortium. On January 5, 2018, the McCarvers

amended their complaint to add their insurer, GEICO, due to its underinsured motorist

coverage because it was learned during discovery that Bogan’s automobile-liability-insurance

policy limit was for only $25,000.00.4 Bogan answered on January 23, 2018, and GEICO

answered on January 29, 2018. Discovery proceeded for the next three months.

¶6. On April 26, 2018, Bogan moved for summary judgment, relying on the notation

3 They were made payable to Washington Group PLLC (an emergency medicine group) for $1,292.00; to Memphis Radiological PC for $890.00; and to MedStat EMS Inc. for $765.00. 4 The amended complaint states that the McCarvers “were an insured under several policies of uninsured/underinsured motorist insurance with GEICO, which policies of insurance provided underinsured motorist coverage in an amount of at least $25,000 per covered vehicle.”

4 listed on the front of the first check. According to Bogan, the check constituted an accord

and satisfaction, thus barring the McCarvers from seeking additional funds from Bogan. On

May 16, 2018, GEICO joined and supplemented Bogan’s summary judgment motion. The

McCarvers responded in opposition on July 6, 2018, and asserted that Bogan and GEICO’s

proof failed to satisfy the elements of an accord and satisfaction. In support of their

argument, McCarver attached an affidavit that read in part:

After the payoff, my wife and I called the adjustor for Allstate and informed him that we had additional property damages that were not reflected in the base value of the truck paid off by GEICO. Specifically, the loss of the rebate, the increased down payment, tinted windows, and a toolbox.

The Allstate adjustor informed me that Allstate was not responsible for the rebate loss and the additional down payment. However, the adjuster did come to my body shop and give me a check for $2,160.00, which the adjustor represented was for my additional property damage, like the tinted windows, and the toolbox.

I never discussed my claims for bodily injury with the Allstate adjustor.

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Richard and Cynthia McCarver v. Richard L. Bogan and Government Employees Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-and-cynthia-mccarver-v-richard-l-bogan-and-government-employees-missctapp-2020.