Rubinstein, A. v. Erie Insurance Exchange

CourtSuperior Court of Pennsylvania
DecidedMay 25, 2022
Docket1353 WDA 2021
StatusPublished

This text of Rubinstein, A. v. Erie Insurance Exchange (Rubinstein, A. v. Erie Insurance Exchange) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rubinstein, A. v. Erie Insurance Exchange, (Pa. Ct. App. 2022).

Opinion

J-A12015-22

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

ANDREW RUBINSTEIN AND JESSICA : IN THE SUPERIOR COURT OF RUBINSTEIN, HIS WIFE, : PENNSYLVANIA INDIVIDUALLY AND ON BEHALF OF : ALL OTHERS SIMILARLY SITUATED : : Appellants : : : v. : No. 1353 WDA 2021 : : ERIE INSURANCE EXCHANGE :

Appeal from the Order Entered November 8, 2021 In the Court of Common Pleas of Indiana County Civil Division at No(s): No. 10858 - CD - 2019

BEFORE: MURRAY, J., McCAFFERY, J., and COLINS, J.*

MEMORANDUM BY McCAFFERY, J.: FILED: MAY 25, 2022

Andrew Rubinstein and Jessica Rubinstein, his wife, individually and on

behalf of all others similarly situated (collectively, “Appellants”) appeal from

the November 8, 2021, order of the Indiana County Court of Common Pleas,

which granted Erie Insurance Exchange’s (“Erie”) motion for summary

judgment in this class action lawsuit concerning an automobile insurance

policy (“Policy”). As will be discussed in detail below, although Appellants

requested that their son be added to the Policy shortly after he turned 16

years old, he was not officially added until approximately 13 months later.

Erie charged Appellants for premiums related to that period. Central to

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-A12015-22

Appellants’ dispute is their allegation that Erie acted improperly by

retroactively charging increased premiums and backdating changes to the

Policy where no claims were paid during the backdated period. Relatedly, they

contend the trial court erred and abused its discretion by: (1) not determining

there were ambiguities in the Policy language and that Erie may only charge

increased premiums from the date a change was made; (2) applying a public

policy analysis to their interpretation of the Policy; (3) basing its decision on

assumptions and speculation; and (4) concluding that the Policy language

permits Erie to backdate changes and charge a retroactively increased

premium to the date within any prior policy period, including the inception of

the Policy. Upon review, we affirm.

The trial court set forth the underlying factual history as follows:

In early April 2018, [Appellants] applied for and were issued an automobile insurance policy by [Erie]. [Appellants] obtained the Policy through one of [Erie]’s local agents, Thomas M. Frick Insurance Agency, LLC, (“Agent”), with an initial term from April 9, 2018 through April 9, 2019. The Agent is not a party to the instant action. [Appellants’] teenage son obtained his driver’s license on April 24, 2018, and [they] maintain that they notified Agent of the same so that he could be added to the Policy. On or about July 16, 2018, [Appellants] informed [Erie] that . . . Andrew Rubinstein had been in an accident, and shortly thereafter, on July 19, 2018, . . . Jessica Rubinstein contacted [Erie], seeking to change their automobile coverage from limited tort to full tort. Approximately thirteen (13) months later, on or about May 17, 2019, [Appellants] became aware that their son had not been added to the Policy and contacted [Erie] regarding this issue. [Appellants] then received a letter from [Erie] with enclosed Amended Declarations for their Policy. Effective as of April 24, 2018, [Appellants’] son was added to the Policy, resulting in a retroactive premium increase of $1517.00. The Amended Declarations also included the full tort coverage for [Appellants’]

-2- J-A12015-22

son, effective as of July 19, 2018, resulting in a retroactive premium charge of $482.00.

Trial Ct. Op., 11/8/21, at 2.

It is not disputed that during the time period when Appellants’ son was

not officially added to the Policy, no claims were made or paid on the son’s

behalf or in relation to any conduct taken by him.

In May 2019, Appellants instituted this lawsuit by filing a class action

complaint, and subsequently filed a second amended complaint in August

2019, raising four counts: (1) violation of the Pennsylvania Unfair Trade

Practices and Consumer Protection Law (UTPCPL);1 (2) breach of contract; (3)

declaratory and injunctive relief pursuant to Pennsylvania’s Declaratory

Judgment Act;2 and (4) unjust enrichment.

In June 2021, Erie filed a motion for summary judgment, alleging: (1)

the Policy “expressly states that the Policy premium may be increased

effective the date that a material change in the Policy occurs, such as the

addition of a licensed driver to the insureds’ household[;]” (2) the clear and

unambiguous Policy terms require the Policy premium to change effective as

of the date the changed occurred[;]” (3) Appellants “failed to establish that

Erie ha[d] engaged in any unfair or deceptive trade practices[;]” (4) Erie “did

not breach its contact with [Appellants], or engage in any unlawful conduct,

1 73 P.S. § 201-1 et seq.

2 42 Pa.C.S. § 7531 et seq.

-3- J-A12015-22

as the clear and unambiguous language of the Policy gives Erie the express

authority to adjust [Appellants’] premium effective as of the date the change

occurred;” and (5) because a valid and enforceable contract exists between

the parties, Appellants “cannot establish that Erie was unjustly enriched by

requesting and/or receiving the premium due under the Policy.” Erie

Insurance Exchange’s Motion for Summary Judgment, 6/1/21, at 1-2.

Appellants filed a brief in opposition to Erie’s motion for summary

judgment, asserting: (1) Erie’s “companywide policy of retroactively

increasing premiums for backdated changes, while not paying related claims,

defeats a significant purpose” of the Pennsylvania Motor Vehicle Financial

Responsibility Law (“MVFRL”);3 (2) certain language in the Policy was

ambiguous; (3) Erie breached the Policy when, rather than canceling the

Policy, it backdated the addition of the Appellants’ son to the policy; and (4)

Erie breached the Policy by backdating the addition of Appellants’ son to the

Policy within their previous policy period. Plaintiffs’ Brief in Opposition to

Defendant’s Motion for Summary Judgment, 6/29/21, at 3, 22-38. Appellants

also suggested that the trial court should deny the motion for summary

judgment, which sought declaratory and injunctive relief, because Erie

breached and continued to breach its policies with Appellants and the

proposed class members. See id. at 38.

3 75 Pa.C.S. § 1701 et seq.

-4- J-A12015-22

On August 17, 2021, the court held argument on the matter. At that

time, Appellants conceded that summary judgment was proper as to UTPCPL

and unjust enrichment counts. See Order of Court, 11/8/21. On November

8, 2021, the court granted Erie’s motion for summary judgment on the

remaining counts. Appellants filed this timely appeal.4

Appellants raise the following issues for our review:

A. Whether the trial court abused its discretion and/or committed an error of law when granting Erie’s [motion for summary judgment] based on the conclusion that the Policy language is not ambiguous?

B. Whether the trial court abused its discretion and/or committed an error of law when granting Erie’s [motion for summary judgment] based on the conclusion that a company-wide practice of backdating policy changes and charging insureds retroactively increased premiums when no related claims were made is consistent with the intent and purpose of the [MVFRL]?

C.

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Bluebook (online)
Rubinstein, A. v. Erie Insurance Exchange, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rubinstein-a-v-erie-insurance-exchange-pasuperct-2022.