R&M Materials Handling, Inc. v. Cincinnati Ins. Co.

2014 Ohio 949
CourtOhio Court of Appeals
DecidedMarch 14, 2014
Docket2013-CA-40
StatusPublished
Cited by2 cases

This text of 2014 Ohio 949 (R&M Materials Handling, Inc. v. Cincinnati Ins. Co.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
R&M Materials Handling, Inc. v. Cincinnati Ins. Co., 2014 Ohio 949 (Ohio Ct. App. 2014).

Opinion

[Cite as R&M Materials Handling, Inc. v. Cincinnati Ins. Co., 2014-Ohio-949.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT CHAMPAIGN COUNTY

R&M MATERIALS HANDLING, INC.

Plaintiff-Appellee/Cross-Appellant

v.

THE CINCINNATI INSURANCE CO.

Defendant-Appellant/Cross-Appellee

Appellate Case No. 2013-CA-40

Trial Court Case No. 2011-CV-154

(Civil Appeal from (Common Pleas Court) ...........

OPINION

Rendered on the 14th day of March, 2014.

...........

TODD A. BRENNER, Atty. Reg. No. 0051839, 555 Metro Place North, Suite 225, Dublin, Ohio 43017 Attorney for Plaintiff-Appellee/Cross-Appellant

RICHARD M. GARNER, Atty. Reg. No. 0061734, DENNIS R. FOGARTY, Atty. Reg. No. 0055563, 1200 Fifth Third Center, 600 Superior Avenue, East, Cleveland, Ohio 44114 Attorney for Defendant-Appellant/Cross-Appellee

............. 2

WELBAUM, J.

{¶ 1} Defendant-Appellant/Cross-Appellee, The Cincinnati Insurance Company,

appeals from the decision of the Champaign County Court of Common Pleas granting summary

judgment in favor of Plaintiff-Appellee/Cross-Appellant, R&M Materials Handling, Inc., on its

supplemental complaint filed pursuant to R.C. 3929.06. R&M Materials Handling, Inc. has also

filed a cross-appeal from the trial court's decision regarding the amount of prejudgment interest it

was awarded. For the reasons outlined below, we reverse the judgment of the trial court and

remand the cause for further proceedings.

I. Facts and Course of Proceedings

{¶ 2} On March 17, 2004, R&M Materials Handling, Inc. (R&M), filed a complaint

against Paris Parts, LLC (Paris Parts), as well as four other defendants, in the United States

District Court for the Southern District of Ohio. As part of its complaint, R&M alleged claims

of copyright infringement, copyright conversion, trademark infringement, trademark

disparagement, misappropriation of trade secrets, breach of fiduciary duty, tortious interference

with business relationships, unfair competition, deceptive trade practices, and unjust enrichment.

When the lawsuit commenced, Paris Parts was insured by The Cincinnati Insurance Company

(CIC), under an insurance policy that included commercial general liability coverage. As a

result, Paris Parts forwarded R&M’s complaint to CIC and requested CIC to defend and

indemnify the company. By letter dated June 7, 2004, CIC determined that no coverage existed

under the policy for R&M’s claims, and it declined to defend and indemnify Paris Parts.

{¶ 3} During the course of litigation, R&M voluntarily dismissed the complaint against 3

Paris Parts only to refile the action in the District Court on May 15, 2006. The refiled complaint

removed one defendant and limited R&M’s claims to misappropriation of trade secrets,

trademark infringement, trademark disparagement, unfair competition, tortious interference with

business relations, and deceptive trade practices. On July 15, 2010, an agreed judgment was

entered against Paris Parts on all counts asserted in the refiled complaint. Thereafter, on August

19, 2010, the District Court awarded R&M damages in the amount of $2,281,934 plus interest

from the date of judgment and costs. CIC was first notified of the refiled action two months

after R&M was awarded the judgment.

{¶ 4} Paris Parts did not satisfy the judgment, so on June 10, 2011, R&M filed a

supplemental complaint for damages against CIC pursuant to R.C. 3929.06 in the Champaign

County Court of Common Pleas. The supplemental complaint alleged that CIC was required to

indemnify Paris Parts under its insurance policy and pay R&M the policy’s $1,000,000 liability

limit. Specifically, R&M alleged that the policy provided liability coverage for “advertising

injury,” and that said coverage was triggered by its trademark infringement claim against Paris

Parts.

{¶ 5} Thereafter, R&M and CIC filed cross-motions for summary judgment on the

supplemental complaint. CIC contended in its motion that there was no genuine issue of

material fact that coverage does not exist for Paris Parts under the “advertising injury” provisions

of the policy because: (1) R&M’s damages did not arise from an “advertising injury” as defined

in the policy; (2) an advertising injury was not caused in the course of advertising Paris Parts’s

goods, products, or services during the policy period; (3) the policy’s various exclusions preclude

coverage; and (4) Paris Parts failed to comply with a precondition to coverage when it did not 4

notify CIC of the refiled lawsuit. In support of its motion for summary judgment, CIC attached

all relevant pleadings and correspondences, the policy at issue, and an affidavit of CIC’s Casualty

Claims Superintendent, Michael Lally.

{¶ 6} R&M argued in its motion for summary judgment that there is no genuine issue

of material fact that the trademark claims alleged against Paris Parts triggered coverage under the

policy as an “advertising injury” given that the trademark claims stemmed from Paris Parts

improperly advertising and marketing R&M’s products. Additionally, R&M claimed that the

policy’s exclusions do not preclude coverage because they only apply to advertising injuries

based on libel, slander, disparagement, and invasion of privacy. R&M also contended that there

was no genuine issue of material fact that CIC declined to defend or indemnify Paris Parts after it

obtained notice of the original lawsuit in 2004, and that said denial waived Paris Parts’s

obligation to abide by the policy’s notice conditions. In support of its cross-motion for summary

judgment, R&M merely attached the underlying complaint from 2004 and the corresponding civil

coversheet.

{¶ 7} The trial court denied CIC’s motion for summary judgment, but granted summary

judgment in favor of R&M in the amount of the policy’s $1,000,000 liability limit. In so

holding, the trial court made no findings of fact and did not specify the amount of prejudgment

interest to be awarded R&M. As a result, R&M filed a motion for prejudgment interest arguing

that it was entitled to interest from June 7, 2004, the date that CIC refused to defend and

indemnify it, which amounted to $448,100. The trial court, however, determined that R&M was

entitled to prejudgment interest from September 18, 2010, the date on which R&M became

eligible to assert a claim against CIC under R.C. 3929.06, which amounted to $77,123.29. 5

{¶ 8} CIC now appeals from the trial court’s decision granting summary judgment in

favor of R&M, raising one assignment of error. R&M has also filed a cross-appeal regarding the

award of prejudgment interest and raises one assignment of error.

II. Assignment of Error

{¶ 9} CIC’s sole assignment of error is as follows:

THE TRIAL COURT COMMITTED REVERSIBLE ERROR BY GRANTING

PLAINTIFF-APPELLANT R&M MATERIALS HANDLING INC.’S MOTION

FOR SUMMARY JUDGMENT AND OVERRULING

DEFENDANT-APPELLEE THE CINCINNATI INSURANCE COMPANY’S

MOTION FOR SUMMARY JUDGMENT.

{¶ 10} Under this assignment of error, CIC contends that the trial court erred in granting

summary judgment in favor of R&M on the issue of coverage because: (1) Paris Parts did not

cause an “advertising injury” as defined by the policy; (2) an advertising injury was not caused in

the course of advertising Paris Parts’s goods, products, or services during the policy period; (3)

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