Sibley v. Gov't Employees Ins. Co.

CourtSuperior Court of Maine
DecidedMay 12, 2000
DocketANDcv-99-56
StatusUnpublished

This text of Sibley v. Gov't Employees Ins. Co. (Sibley v. Gov't Employees Ins. Co.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sibley v. Gov't Employees Ins. Co., (Me. Super. Ct. 2000).

Opinion

*ECEIVED & FILED

STATE OF MAINE APR 25 2000 suPERIOR COURT ANDROSCOGGIN, ss. ANDROSCOGGIN CIVIL ACTION SUPERIOR COURT DOCKET NO. CV--99-56

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Plaintiffs Soot

DENNIS SIBLEY and JOANNE SIBLEY,

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pubis

Vv.

GOVERNMENT EMPLOYEES L ceapseres ee. INSURANCE COMPANY, H seem DECISION AND ORDER

Defendant

This matter is before the Court on Defendant GEICO’s Motion for Summary Judgment. For the following reasons, Defendant’s Motion is DENIED.

FACTS

On November 16, 1995, Dennis Sibley was driving a truck in Portland, Maine when his vehicle collided with a vehicle operated by Beryl Hall. Mr. Sibley alleges that he sustained serious injuries as a result of Ms. Hall’s negligence. At the time of the accident, Mr. Sibley carried an automobile liability policy issued by Government Employees Insurance Company “GEICO” with a liability limit of $300,000 per person/$300,000 per accident. Ms. Hall in turn carried an automobile liability policy with a liability limit of $100,000 per person/ $100,000 per accident.

The Sibleys initially settled their claim against Beryl Hall’s insurer for $85,000.' Simultaneously, they signed a Release of All Claims and Indemnity

Agreement in favor of Ms. Hall and her insurer. The Sibleys did not obtain the prior

1 This was $15,000 less than the maximum amount of $100,000 that Plaintiffs could potentially have been awarded. consent of GEICO before making the settlement agreement. Consequently, when the Sibleys demanded underinsured motorist benefits from GEICO-two days later, GEICO denied their claim. GEICO rationalized its rejection by citing language from the policy which precludes settlement with a tortfeasors’s insurer without GEICO’s advance approval.

Subsequently, the Sibleys commenced a suit against GEICO, seeking compensation for any damages in excess of $100,000, the maximum liability limit of the Beryl Hall policy.2 GFICO continues to deny liability and now moves for summary judgment. GEICO urges this Court to find as a matter of law that the release executed by the Sibleys bars them from obtaining excess liability coverage. The Sibleys in turn present this Court with their own motion for partial summary judgment, asking this Court to find GEICO liable for any damages that exceed $100,000, should liability be established.

DISCUSSION

The Sibleys are not required to first exhaust their remedy against Ms. Hall’s insurance company before pursuing a claim against GEICO.

GEICO argues that pursuant to 24-A MRSA § 2902 (4), the Sibleys are required

to first exhaust their remedy against Ms. Hall’s insurance company before pursuing a claim against GEICO. GEICO’s argument, however flies in the face of recent precedent set by the Law Court in Greenvall v. Maine Mut. Fire Ins. Co., 1998 ME 204, J 715 A.2d 949.

Greenvall supports the Sibleys’s assertion that an insured may recover

2 The Plaintiffs stipulated that GEICO was entitled to a set-off of $100,000, the maximum amount of coverage under Beryl Hall’s policy.

3 Section 2902 (4) states: In the event of payment to any person under uninsured vehicle coverage, and subject to the terms of such coverage, to the extent of such payment the insurer shall be entitled to the proceeds of any settlement or recovery from any person legally responsible for the bodily injury as to which such payment was made, and to amounts recoverable from the assets of the insolvent insurer of the other motor vehicle.

uninsured motorist benefits without first securing a judgment against the uninsured tortfeasor. The Law Court explained that “because the insured’s legal entitlement to recovery against the underinsured motorist and the insurer’s contract liability can be resolved in a single action, considerations of judicial economy militate against requiring a judgment against the underinsured tortfeasor before suit may be brought against the insurer.”Id. ¥ 7,715 A.2d at 952.

GEICO attempts to distinguish Greenvall from the case at bar, stating that the settlement in Greenvall was for the $100,000 policy limits. In contrast, the settlement in this case was for $15,000 less than the policy limit. GEICO concludes that as a result, a condition precedent to the Sibleys’ recovery has not been satisfied, and their claim is barred. GEICO’s attempt to avoid liability by such a technicality is not persuasive, especially where the Sibleys concede that GEICO is entitled to the full $100,000 setoff.

Additionally, the Law Court in Bazinet v. Concord General Mutual Insurance Company , 513 A.2d 279 (Me. 1986) held that where there is joint and. several liability between multiple insurers, any arbitrary distinction between excess and primary carriers should be rejected. A plaintiff is not required to exhaust the entire amount of coverage provided by one carrier before demanding compensation from the other.

Under this rule an insured has the right to proceed against any and all of the carriers who may be liable to him up to the stated policy limit, and any excess/primary distinction sought to be drawn by an insurer has no bearing on that right..

Thus an injured passenger can settle with the driver’s insurer for an amount less than the policy limit and then proceed against his own carrier for the remainder of his actual damages [citing caselaw] [emphasis added] 4

GEICO additionally argues that the release signed by the Sibleys effectively

destroyed its subrogation rights. GEICO however has not demonstrated any real

4 Id. J 2,279 A.2d at 281 prejudice to its subrogation rights. “When an insured settles with an underinsured tortfeasor, the insurer must demonstrate prejudice as a result of the loss of subrogation rights before the insurer may deny recovery under the policy.” Greenvall, 1998 ME 204, J 12, 715 Ad. at 954.

GEICO could demonstrate prejudice by showing that Ms. Hall has sufficient assets to satisfy a judgment in favor of GEICO. Until or unless GEICO can provide affidavits or other records supporting such a claim, the Court will not consider granting the motion for summary judgment.

Wherefore the entry shall be: Defendant’s motion for summgey judgment is

DENIED. Plaintiff’s Partial Motion for Summary Judgment

2h Date: April % 2000

Rofand A. Cole Jastice, Superior Court

STATE OF MAINE ECEIVED & FLED ANDROSCOGGIN, SS. May 12 2009

SUPERIOR COURT CIVIL ACTION DOCKET NO. CV-99-56

JED-AND- SJialaawo

ANDROSCOGGIN

DENNIS SIBLEY and SUPERIOR COURT

JOANNE SIBLEY, Plaintiffs Vv. DECISION AND JUDGMENT

GOVERNMENT EMPLOYEES INSURANCE COMPANY,

Plaintiff Dennis Sibley was injured in a motor vehicle accident in Portland on November 16, 1995. His claim against the driver of the other vehicle, Beryl Hall, was settled for $85,000. He has initiated this action against his own insurer, Government Employees Insurance Company (GEICO), pursuant to 24-A M.R.S.A. § 2902 and the underinsured motorist provision of the policy issued to plaintiffs by defendant. The plaintiffs seek damages from GEICO in excess of $100,000, which is the upper limit of coverage available through the tortfeasor, Beryl Hall.

Dennis Sibley was the driver of a Brinks armored car at the time of the accident which caused his right hand and arm to go through the steering wheel causing a severe fracture and dislocation of the right wrist.

After an initial evaluation at Mercy Hospital in Portland, he was transported to Central Maine Medical Center in Lewiston, where an orthopedic surgeon performed a closed reduction to repair the fracture. This procedure proved

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Related

Bazinet v. Concord General Mutual Insurance
513 A.2d 279 (Supreme Judicial Court of Maine, 1986)
Greenvall v. Maine Mutual Fire Insurance
1998 ME 204 (Supreme Judicial Court of Maine, 1998)

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Bluebook (online)
Sibley v. Gov't Employees Ins. Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/sibley-v-govt-employees-ins-co-mesuperct-2000.