Security National Insurance Company v. Construction Associates of Spokane Inc

CourtDistrict Court, E.D. Washington
DecidedMarch 1, 2021
Docket2:20-cv-00167
StatusUnknown

This text of Security National Insurance Company v. Construction Associates of Spokane Inc (Security National Insurance Company v. Construction Associates of Spokane Inc) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Security National Insurance Company v. Construction Associates of Spokane Inc, (E.D. Wash. 2021).

Opinion

1 EASTERN DISTRICT OF WASHINGTON Mar 01, 2021

2 SEAN F. MCAVOY, CLERK

3 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 4 SECURITY NATIONAL No. 2:20-cv-00167-SMJ 5 INSURANCE COMPANY, ORDER DENYING MOTION FOR 6 Plaintiff, RECONSIDERATION

7 v.

8 CONSTRUCTION ASSOCIATES OF SPOKANE, INC.; and MARK AND 9 JENNIFER WILSON,

10 Defendants.

12 Before the Court is Security National Insurance Company’s (“Security 13 National”) motion for reconsideration, ECF No. 55. Security National asks the 14 Court to reconsider the portion of its Order Granting Motion to Strike and Motions 15 to Quash, ECF No. 45, which quashed certain sections of two subpoenas for 16 overbreadth and for seeking materials protected by the work-product doctrine and 17 the attorney-client privilege. Having reviewed the briefing and file in this matter, 18 the Court is fully informed and denies the motion for reconsideration. 19 // 20 // 1 BACKGROUND 2 A. Allegations and State Court Procedural History

3 Intervenor Defendant Mark Wilson was electrocuted and suffered severe 4 injuries on a construction project where Defendant Construction Associates of 5 Spokane, Inc. (“CAS”) was the general contractor and Merit Electric was a

6 subcontractor. See ECF No. 1 at 3–4; ECF No. 30-1. Mark and Jennifer Wilson sued 7 for personal injury in Spokane County Superior Court. See ECF No. 1 at 2. CAS 8 sought indemnity from Security National, which denied that it had any duty to CAS. 9 See id. Security National insured Merit Electric and CAS claims that it was an

10 additional insured on the applicable insurance policy. See id. Security National’s 11 authorized agent had provided a certificate of liability insurance to CAS, but 12 Security National asserts that CAS obtained the certificate under false pretenses.

13 ECF No. 1 at 4–6; ECF No. 18 at 10–11. 14 CAS and the Wilsons later settled the Spokane County case for $1 million and 15 a covenant judgment against Security National of $7.5 million. See ECF No. 23 at 16 9. As part of the settlement, CAS assigned to the Wilsons the claim against Security

17 National for bad faith. See id. at 14. The Spokane County case remains open pending 18 a reasonable determination by the court. 19 //

20 // 1 B. This Action 2 Security National sues for common law misrepresentation and

3 misrepresentation under Washington Revised Code § 48.01.030 and seeks a 4 declaratory judgment that Defendant CAS does not qualify as an additional insured 5 and is not entitled to coverage, as well as monetary damages. ECF Nos. 1, 23. The

6 Wilsons and CAS bring counterclaims against Security National for breach of 7 contract, violation of the Washington Insurance Fair Conduct Act, Washington 8 Revised Code § 48.30.015, violation of the Washington Consumer Protection Act, 9 Washington Revised Code § 19.86, et seq., violation of the duty of good faith (bad

10 faith), negligence, coverage by estoppel, and damages and fees. ECF Nos. 18, 21. 11 Security National asserts affirmative defenses that the Defendants’ claims are barred 12 by unclean hands, waiver, estoppel, fraud, affirmative misrepresentations,

13 representations by omission, and bad faith conduct. ECF Nos. 20, 23. 14 LEGAL STANDARD 15 Reconsideration is an “extraordinary remedy, to be used sparingly in the 16 interests of finality and conservation of judicial resources.” Kona Enterprises, Inc.

17 v. Estate of Bishop, 229 F.3d 877, 890 (9th Cir. 2000). A motion for reconsideration 18 may be reviewed under either Federal Rule of Civil Procedure 59(e) (motion to alter 19 or amend a judgment) or 60(b) (relief from judgment). Sch. Dist. No. 1J v. ACandS,

20 Inc., 5 F.3d 1255, 1262 (9th Cir. 1993). “A district court may properly reconsider 1 its decision if it ‘(1) is presented with newly discovered evidence, (2) committed 2 clear error or the initial decision was manifestly unjust, or (3) if there is an

3 intervening change in controlling law.’” Smith v. Clark Cnty. Sch. Dist., 727 F.3d 4 950, 955 (9th Cir. 2013) (quoting Sch. Dist. No. 1J, 5 F.3d at 1263). “There may 5 also be other, highly unusual, circumstances warranting reconsideration.” Sch. Dist.

6 No. 1J, 5 F.3d at 1263. Courts generally disfavor motions for reconsideration and 7 they may not be used to present new arguments or evidence that could have been 8 raised earlier. Fuller v. M.G. Jewelry, 950 F.2d 1437, 1442 (9th Cir.1991). 9 DISCUSSION

10 With its sweeping subpoenas, Security National asks this Court to allow it to 11 go on a fishing expedition into privileged materials to find evidence of 12 unreasonableness. Security National’s motion largely relies on its analysis of a 2016

13 case which it failed to cite in its previous briefing. See Steel v. Olympia Early 14 Learning Ctr., 381 P.3d 111 (Wash. App. 2016); see also ECF No. 29. Review of 15 this case does not change the Court’s determination that the attorney-client privilege 16 remains in full force.

17 If the existance of a covenant judgment could itself overwhelm the privilege, 18 courts would automatically waive it in cases such as this. Instead, “a party who 19 seeks to apply Hearn’s implied waiver test must bear a significant burden.” Steel,

20 381 P.3d at 119 (citing Hearn v. Rhay, 68 F.R.D. 574 (E.D. Wash. 1975) (setting 1 forth the standard for waiver of the attorney-client privilege)). Security National has 2 not met that burden. It argues that “all settlements with covenant judgments –

3 including the one between the Wilsons and CAS – involve adversaries joining 4 together to ‘set up’ the insurer for a follow-on bad faith action. Accordingly, these 5 schemes inherently involve some degree of collusion.” ECF No. 55 at 6 (emphasis

6 in original). But if the danger of collusion could create an implied waiver, it would 7 exist in every case. Again, it does not. Nor does it exist here. 8 Security National argues that the parties have waived the attorney-client 9 privilege for information related to the Glover/Chaussee factors1 for determining

10 the reasonableness of the state court settlement and covenant judgment. A party 11 waives the privilege if (1) the assertion of the privilege stems from an affirmative 12 act by the asserting party; (2) the asserting party put the protected information at

14 1 As described in its Order to Quash, ECF No. 45 at 17, the Washington State Supreme Court has set out nine factors for courts to consider in determining the 15 reasonableness of a settlement and covenant judgment:

16 (1) [T]he releasing party’s damages; (2) the merits of the releasing party’s liability theory; (3) the merits of the released party’s defense 17 theory; (4) the released party’s relative fault; (5) the risks and expenses of continued litigation; (6) the released party’s ability to pay; (7) any 18 evidence of bad faith, collusion, or fraud; (8) the extent of the releasing party’s investigation and preparation; and (9) the interests of the parties 19 not being released.

20 See Glover v. Tacoma Gen. Hosp., 658 P.2d 1230, 1236 (Wash. 1983); Chaussee v. Maryland Cas. Co., 803 P.2d 1339, 1344 (Wash. App. 1991). 1 issue; and (3) application of the privilege would deny the opposing party access to 2 information vital to its defense. Hearn, 68 F.R.D. at 581; see also Pappas v.

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Related

Khan v. Holder
727 F.3d 1 (First Circuit, 2013)
Chaussee v. Maryland Casualty Co.
803 P.2d 1339 (Court of Appeals of Washington, 1991)
Glover v. Tacoma General Hospital
658 P.2d 1230 (Washington Supreme Court, 1983)
Pappas v. Holloway
787 P.2d 30 (Washington Supreme Court, 1990)
Lisa Steel v. Olympia Early Learning Center
381 P.3d 111 (Court of Appeals of Washington, 2016)
Dana v. Piper
295 P.3d 305 (Court of Appeals of Washington, 2013)
Hearn v. Rhay
68 F.R.D. 574 (E.D. Washington, 1975)
Fuller v. M.G. Jewelry
950 F.2d 1437 (Ninth Circuit, 1991)

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Security National Insurance Company v. Construction Associates of Spokane Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/security-national-insurance-company-v-construction-associates-of-spokane-waed-2021.