Rodeo v. Columbia

CourtNew Mexico Court of Appeals
DecidedAugust 20, 2009
Docket28,384
StatusUnpublished

This text of Rodeo v. Columbia (Rodeo v. Columbia) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodeo v. Columbia, (N.M. Ct. App. 2009).

Opinion

1 This memorandum opinion was not selected for publication in the New Mexico Reports. Please 2 see Rule 12-405 NMRA for restrictions on the citation of unpublished memorandum opinions. 3 Please also note that this electronic memorandum opinion may contain computer-generated 4 errors or other deviations from the official paper version filed by the Court of Appeals and does 5 not include the filing date.

6 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

7 RODEO, INC., a New Mexico 8 corporation, d/b/a “COWBOYS”; 9 GENE HINKLE, individually; 10 HINKLE INVESTMENTS a/k/a 11 HINKLE INCOME PROPERTIES, 12 LLC, and RITA TRUJILLO,

13 Third-Party Plaintiffs/Appellees/ 14 Cross-Appellants,

15 v. NO. 28,384 & 28,445 16 (Consolidated) 17 COLUMBIA CASUALTY INSURANCE 18 COMPANY,

19 Third-Party Defendant/Appellant/ 20 Cross-Appellee.

21 APPEAL FROM THE DISTRICT COURT OF VALENCIA COUNTY 22 William A. Sanchez, District Judge

23 L. Helen Bennett 24 Steven Vogel 25 Bryan Query 26 Albuquerque, NM

27 for Appellees

28 Yenson, Lynn, Allen & Wosick, P.C. 29 Patrick D. Allen 30 Patricia A. Padrino 1 Albuquerque, NM

2 for Appellant

3 MEMORANDUM OPINION

4 VANZI, Judge.

5 In this consolidated appeal and cross-appeal, which stems from an action for

6 breach of contract, bad faith and breach of fiduciary duty, and violations of the New

7 Mexico Insurance Code and Unfair Practices Act, the trial court’s awards of attorney

8 fees, costs, and prejudgment interest are contested. In addition, Appellees challenge

9 the trial court’s admission of certain testimony at trial. We hold that the trial court

10 erred in finding, for purposes of awarding attorney fees under NMSA 1978, Section

11 39-2-1 (1977), that Appellant’s failure to provide insurance coverage was

12 unreasonable. Accordingly, we reverse the trial court’s award of attorney fees under

13 Section 39-2-1. We affirm on all other grounds.

14 BACKGROUND

15 Origin of This Litigation and Identity of the Parties

16 This is the second appeal to this Court concerning third-party claims by a bar

17 owner against its insurer after being sued for the wrongful death of a patron. The facts

18 which gave rise to the original controversy are set forth in detail in this Court’s

19 previous opinion, Rodeo, Inc. v. Columbia Casualty Co., 2007-NMCA-013, 141 N.M.

2 1 32, 150 P.3d 982 (hereinafter Rodeo I). This second appeal concerns the trial court’s

2 rulings regarding attorney fees, costs, prejudgment interest, and the trial court’s

3 admission of certain testimony at trial.

4 Appellant is the Columbia Casualty Insurance Company (Columbia). Columbia

5 provided commercial general liability and liquor liability insurance for Cowboys.

6 Appellees are all associated with Cowboys: Rodeo, Inc. (Rodeo) is the business entity

7 which owns and operates Cowboys; Gene Hinkle leased the property on which

8 Cowboys is located; and Rita Trujillo owned Cowboys’ liquor license. Hinkle and

9 Trujillo were both named as additional insureds in the Columbia policy. We refer to

10 Rodeo, Hinkle, and Trujillo collectively as Appellees.

11 Rodeo obtained the insurance policy from Columbia through a premium finance

12 agreement. Under this agreement, the finance company paid the annual premium in

13 full to Columbia, and Rodeo paid the finance company monthly premium payments.

14 The agreement required Rodeo to provide the finance company with power of attorney

15 and also required Rodeo to accept the following condition: In the event Rodeo failed

16 to make timely monthly premium payments, the finance company would take the

17 necessary steps to terminate the Columbia policy.

18 In the months immediately preceding the death of the Cowboys patron, Rodeo

19 failed to make timely insurance premium payments. As a result, the finance company

3 1 initiated the process of canceling the policy, and Appellees were ultimately informed

2 that their liability insurance had been canceled. Appellees maintained that Columbia

3 was without grounds to cancel their insurance policy and brought suit against

4 Columbia. In that third-party complaint and the subsequently filed amended third-

5 party complaint, Appellees argued that Columbia had a duty to defend and indemnify

6 them in the wrongful death action and claimed breach of contract, bad faith and breach

7 of fiduciary duty, and violations of the New Mexico Insurance Code and Unfair

8 Practices Act.

9 The trial court ruled that Appellees’ insurance policy had not been canceled at

10 the time the wrongful death suit was filed, and we agreed. Rodeo I, 2007-NMCA-013,

11 ¶¶ 8-9. In Rodeo I, issued on October 27, 2006, we held as a matter of first impression

12 that an insurance contract obtained through an insurance premium finance agreement

13 cannot be canceled under NMSA 1978, Section 59A-45-11(A) (1984) unless the

14 insurer was in compliance with all of the subsections of Section 59-45-11. Rodeo I,

15 2007-NMCA-013, ¶ 1. We observed in Rodeo I that Rodeo obtained the policy from

16 Columbia through a premium finance agreement and that Columbia had not complied

17 with Subsection (E) (requiring Columbia to return the unearned premium before

18 canceling Appellees’ policy) at the time the wrongful death suit had been filed. Id.

4 1 ¶¶ 33-34. Thus, we concluded that Appellees’ policy had not been cancelled when the

2 wrongful death suit was filed. Id.

3 After we issued Rodeo I and on remand, Columbia assumed the representation

4 of Rodeo and Trujillo in the wrongful death suit. Columbia settled the claims against

5 Rodeo and Trujillo arising from the wrongful death suit and reimbursed Rodeo and

6 Trujillo for all the attorney fees and costs they incurred defending those claims.

7 Columbia did not provide representation to Hinkle. The parties do not dispute that

8 Hinkle’s insurance provider, Travelers Insurance, covered the costs of that

9 representation and settled all claims against Hinkle arising from the wrongful death

10 suit. According to Columbia, Travelers has not yet requested reimbursement for those

11 costs or filed suit to recoup them.

12 Although all claims against Appellees associated with the wrongful death suit

13 had been settled and dismissed, Appellees’ claims against Columbia remained. These

14 claims proceeded to a jury trial. At the close of trial, the jury returned a verdict in

15 favor of Appellees on the breach of contract claim and against them on the bad faith,

16 violation of New Mexico Insurance Code, and violation of New Mexico Unfair

17 Practices Act claims. On the breach of contract claim, the jury awarded Hinkle and

18 Trujillo $45,000 each in incidental and consequential damages and awarded no

19 damages to Rodeo.

5 1 After trial, Appellees filed motions for attorney fees, costs, and prejudgment

2 interest. Columbia responded that, as the prevailing party at trial, it (not Appellees)

3 was entitled to costs. The trial court denied Columbia’s motion for costs. The trial

4 court also denied Appellees’ request for attorney fees and costs incurred after the

5 issuance of Rodeo I—the attorney fees and costs Appellees expended litigating the

6 breach of contract, bad faith, and Insurance Code and Unfair Practices Act claims.

7 However, citing Section 39-2-1, the trial court ordered Columbia to pay all of

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