Richard Chowning v. Nationwide Insurance Company of America; Allied Insurance Company of America; Nationwide Argibusiness Insurance Company; Titan Insurance Company Inc.; Victoria Fire & Casualty Company and Does I - V, and Roe Corporations I - V, inclusive

CourtDistrict Court, D. Nevada
DecidedNovember 4, 2025
Docket2:22-cv-00798
StatusUnknown

This text of Richard Chowning v. Nationwide Insurance Company of America; Allied Insurance Company of America; Nationwide Argibusiness Insurance Company; Titan Insurance Company Inc.; Victoria Fire & Casualty Company and Does I - V, and Roe Corporations I - V, inclusive (Richard Chowning v. Nationwide Insurance Company of America; Allied Insurance Company of America; Nationwide Argibusiness Insurance Company; Titan Insurance Company Inc.; Victoria Fire & Casualty Company and Does I - V, and Roe Corporations I - V, inclusive) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard Chowning v. Nationwide Insurance Company of America; Allied Insurance Company of America; Nationwide Argibusiness Insurance Company; Titan Insurance Company Inc.; Victoria Fire & Casualty Company and Does I - V, and Roe Corporations I - V, inclusive, (D. Nev. 2025).

Opinion

UNITED STATES DISTRICT COURT 1 DISTRICT OF NEVADA 2 * * * 3 RICHARD CHOWNING, CASE No: 2:22-cv-00798-CDS-EJY 4 Plaintiff, ORDER 5 vs. 6 NATIONWIDE INSURANCE COMPANY OF 7 AMERICA; ALLIED INSURANCE COMPANY OF AMERICA; NATIONWIDE ARGIBUSINESS 8 INSURANCE COMPANY; TITAN INSURANCE COMPANY INC.; VICTORIA FIRE & 9 CASUALTY COMPANY and DOES I - V, and ROE CORPORATIONS I - V, inclusive, 10 Defendants. 11 12 Pending before the Court is Defendants’ Motion for Leave to Amend Their Answers to the 13 First Amended Complaint. ECF No. 91. Also Pending is Plaintiff’s Motion for Leave to File 14 Supplement to Response to Defendants’ Motion for Leave to Amend Answer. ECF No. 106. The 15 Court considered the Motions, respective Responses, and respective Replies. 16 I. Relevant Background 17 Plaintiff filed his Complaint in this action in the Eighth Judicial District Court for Clark 18 County, Nevada in April 2022.1 ECF No. 1 at 10. Defendants removed the action in May 2022. Id. 19 at 1. An Amended Complaint was filed on August 17, 2022 (ECF No. 25), and is the operative 20 complaint in this action at this time. The issue presented is whether Defendants’ Answers to the 21 Amended Complaint may be amended to include an affirmative defense titled: “Failure to 22 Cooperate.” ECF No. 91 at 9. Defendants request no other amendments to their Answers. 23 Defendants contend there is good cause for the amendment because they did not discover the 24 basis for the amended affirmative defense until “mid-February 2023.” Id. at 11. It was at that time 25 Defendants say they first learned that the entire insurance claims file disclosed in this action was 26

1 Underlying this action was a dispute filed by Deeanna Parks (“Parks”) in the Eighth Judicial District Court. 27 Parks was a passenger on a motorcycle owned by Richard Chowning—Plaintiff in this action—and insured, according 1 given to Plaintiff’s rebuttal expert Kimball Jones (“Jones”). Id. Defendants argue the claims file 2 contains documents protected by “the tripartite” attorney client privilege that exists between and 3 among Plaintiff’s counsel, Defendants, and Defendants’ counsel. Id. at 7. In sum, Defendants say 4 that Plaintiff’s disclosure of the privileged information to his rebuttal expert violated the cooperation 5 clause in the policy under which Plaintiff was insured. That clause is quoted by Defendants as 6 requiring Plaintiff to “assist us and, if applicable, the defense counsel chosen for you by us, with any 7 claim or suit…. [and] provide … cooperation to us during any claim or suit for the investigation, 8 settlement or defense of that claim or suit.” Id. at 9 citing ECF No. 18-6 at 19.2 Defendants go on 9 to quote the “General Provisions” of the policy as stating: “We, you, and anyone insured by this 10 policy must do certain things in order for the provisions of the policy to apply. The following are 11 policy conditions: … (8) Legal Action Limitations: No legal action may be brought against the 12 company concerning any of the coverages provided in this policy until the insured has fully complied 13 with all the terms of the policy.” Id. citing id. at 21. Defendants argue they meet the standard 14 applicable to Federal Rule of Civil Procedure 15 because they were diligent in bringing the Motion 15 to Amend, there is no bad faith, there is an absence of delay, there is no prejudice to Plaintiff, and 16 the amendment is not futile. Id. at 12-17. 17 When boiled down to its essence, Plaintiff argues in response that Defendants delayed their 18 filing, the cooperation clause is inapplicable to the facts presented by Defendants, and the proposed 19 amendment is futile. ECF No. 94. That is, Plaintiff contends he shared information with his rebuttal 20 expert (not the public), Defendants identified no limiting designation on the claims file it produced 21 to him, Defendants did not indicate there was anything produced by them in this case that Plaintiff 22 was precluded from providing to his expert, there is no evidence of a request for cooperation of any 23 kind that Plaintiff failed to provide, Defendants suffered no prejudice arising from disclosure of the 24 claims file to Plaintiff’s expert (let alone substantial prejudice as a result of the disclosure), and 25 Plaintiff will suffer substantial prejudice if the amendment requested is permitted. Id., generally. 26 Defendants’ Reply initially focuses on Plaintiff’s “waiver” of the attorney client privilege 27 without Defendants’ agreement to do so. ECF No. 97. This argument was not raised in Defendants’ 1 moving papers. See ECF No. 91. Defendants say there is no implied waiver by virtue of the 2 production of the claims file to Plaintiff, and that Plaintiff could not make the file “public” simply 3 based on Defendants’ production. Id. at 3-4. Defendants also argue collusion (which they mention 4 in their moving papers as well), and more than once contend that Plaintiff has somehow obstructed 5 their defense. ECF Nos. 91 at 8, 12; 97 at 9. Nowhere do Defendants offer any facts to support 6 obstruction. Id. Defendants turn to futility and discuss the limitations of case law interpreting NRS 7 485.3091.5(a) that does not reach “excess of additional coverage … not covered” by the statute.3 8 ECF No. 97 at 10. Defendants state that “[w]hile the statute might make … [them] liable to 9 indemnify … [Plaintiff] up to the statutory minimum amount of liability coverage, it does not 10 preclude … [Defendants] from disclaiming liability beyond that amount based on his violation of 11 the [p]olicy’s cooperation clause.” Id. relying on Torres v. Nev. Direct Ins. Co., 353 P.3d 1203, 12 1207-08 (Nev. 2015) (“we hold that no post-injury violation of a policy will release the insurer under 13 the absolute-liability provision” and “absolute-liability statutes are interpreted to require payment of 14 the minimum statutorily required insurance benefits, if the law required the policy to be in place, 15 even if the insured has breached the insurance contract or made misrepresentations in the insurance 16 application.”) (internal citations omitted). 17 With respect to prejudice, Defendants say that their proposed amended answer begins with 18 the conclusory statement that they have “been prejudiced by … [Plaintiff’s] breach of [his] 19 contractual duties.” ECF No. 97 at 11 citing ECF No. 91-12 at 14 ¶ 92 (second brackets in original). 20 Defendants contends the “[C]ourt must accept” this pleading as true. Id. at 11. Of course, accepting 21 a pleading as true presumes the pleading is filed and presumes what is asserted is fact, not a legal 22 conclusion. Defendants next argue that Nevada law does not require them to show any prejudice 23 arising from Plaintiff’s alleged non-cooperation. Id. Defendants closes out their Reply contending 24 their Motion was not limited to the disclosure of attorney client communications to Plaintiff’s expert, 25 but is broader—that is, the alleged “collusion since” the beginning of the underlying action in state 26 court. Id. at 12. 27 1 II. Discussion 2 a. The Standard Applicable to a Motion to Amend an Answer. 3 The standard for leave to amend a complaint under Rule 15 of the Federal Rules of Civil 4 Procedure applies equally to a request for leave to amend an answer. Lopez v. Swift, Case No. 12- 5 CV-5099-TOR, 2014 WL 2957459, at *4 (E.D. Wash. July 1, 2014). Courts consider five factors 6 in deciding whether to do so: (1) bad faith, (2) undue delay, (3) prejudice to the opposing party, (4) 7 futility of amendment, and (5) whether the pleading has previously been amended. See, e.g., United 8 States v. Corinthian Colleges, 655 F.3d 984, 995 (9th Cir. 2011). Prejudice is given the greatest 9 weight. Eminence Capital, LLC, v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Corinthian Colleges
655 F.3d 984 (Ninth Circuit, 2011)
Martin Fine v. Bellefonte Underwriters Insurance Co.
725 F.2d 179 (Second Circuit, 1984)
Callaway v. Sublimity Insurance
858 P.2d 888 (Court of Appeals of Oregon, 1993)
Lemoge v. United States
587 F.3d 1188 (Ninth Circuit, 2009)
Forest City Grant Liberty Associates v. Genro II, Inc.
652 A.2d 948 (Superior Court of Pennsylvania, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Richard Chowning v. Nationwide Insurance Company of America; Allied Insurance Company of America; Nationwide Argibusiness Insurance Company; Titan Insurance Company Inc.; Victoria Fire & Casualty Company and Does I - V, and Roe Corporations I - V, inclusive, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-chowning-v-nationwide-insurance-company-of-america-allied-nvd-2025.