Skelly and Skelly v. Hertz Equipment Rental Corp.

CourtCourt of Appeals of Virginia
DecidedJanuary 15, 2002
Docket2358002
StatusPublished

This text of Skelly and Skelly v. Hertz Equipment Rental Corp. (Skelly and Skelly v. Hertz Equipment Rental Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Skelly and Skelly v. Hertz Equipment Rental Corp., (Va. Ct. App. 2002).

Opinion

Tuesday 15th

January, 2002.

Shannon P. Skelly and Sarah E. Skelly, as Beneficiaries of Michael L. Skelly, Deceased, Appellants,

against Record No. 2358-00-2 Claim No. 182-60-40

Hertz Equipment Rental Corporation and Reliance National Indemnity Company, Appellees.

Upon a Rehearing En Banc

Before Chief Judge Fitzpatrick, Judges Benton, Willis, Elder, Bray, Annunziata, Bumgardner, Frank, Humphreys, Clements and Agee

Louis D. Snesil (Louis D. Snesil, P.C., on brief), for appellants.

R. Ferrell Newman (Thompson, Smithers, Newman, Wade & Childress, on brief), for appellees.

By published opinion issued June 26, 2001, Skelly v.

Hertz Equipment Rental Corp. & Reliance Nat'l Indem. Co., 35 Va.

App. 689, 547 S.E.2d 551 (2001), a divided panel of this Court

affirmed the judgment of the Virginia Workers' Compensation

Commission. We stayed the mandate of that decision and granted

rehearing en banc.

Upon rehearing en banc, the stay of this Court's June

26, 2001 mandate is lifted and we affirm the judgment of the Workers' Compensation Commission for the reasons set forth in

the majority panel decision.

____________________

Elder, J., with whom Fitzpatrick, C.J., Benton, Annunziata and Frank, JJ., join, dissenting.

I would hold this case is controlled by rather than

distinguishable from Wood v. Caudle-Hyatt, Inc., 18 Va. App.

391, 444 S.E.2d 3 (1994). Here, the claimants notified Hertz of

the proposed settlement and the date on which they hoped to

obtain court approval. The settlement did not impair Hertz's

rights until a valid release was executed, which could not have

occurred until the claimants obtained court approval for the

settlement. Hertz had over four weeks before the court approved

the settlement in which to act, but it failed to voice any

objections during that time. Therefore, I respectfully dissent.

Wood involved a claimant with asbestosis who filed a

claim for workers' compensation benefits against his employer,

Caudle-Hyatt, Inc. Id. at 393, 444 S.E.2d at 5. Wood

simultaneously pursued common law tort actions against various

asbestos manufacturers and negotiated settlement offers for the

tort claims. Id. Wood notified Caudle-Hyatt in writing by

certified mail of the terms of the settlement offers and said he

intended to accept them unless Caudle-Hyatt objected within ten

days. Id. Caudle-Hyatt responded that it was not liable for

Wood's asbestosis claim; it did not agree or object to the

-2- proposed tort settlement or mention any subrogation rights. Id.

at 393-94, 444 S.E.2d at 5. Wood then settled the tort claims

for an amount that exceeded the sum he might have received for

his ailment under the Workers' Compensation Act, exclusive of

medical expenses. Id. at 394, 444 S.E.2d at 5.

On appeal, we held, inter alia, that Wood's claim for

compensation and a pro rata share of attorney's fees from

Caudle-Hyatt was not barred because Wood informed Caudle-Hyatt

of the terms of the settlement and gave it an opportunity to

object or to participate in order to protect its subrogation

rights. Id. at 398-99, 444 S.E.2d at 7-8. In essence, we held

that Caudle-Hyatt consented to the settlement through its

inaction.

Similarly, here, Hertz consented through inaction to

the settlement of the third-party wrongful death claim on behalf

of the claimants. Under general principles of insurance law, an

insurer's subrogation rights are not impaired by a settlement

until a valid release has been executed by one with authority to

do so. See 16 Lee R. Russ & Thomas F. Segalla, Couch on

Insurance 3d § 224:100 (1999); id. § 224:104 ("As with any

contract provision, there must be a meeting of the minds

concerning the terms and conditions of the applicable provision

as well as meeting all other requirements of an enforceable

contract (i.e., authority and consideration)."). Virginia's

-3- wrongful death statutes provide that a decedent's personal

representative may compromise a wrongful death claim only with

court approval. See Code § 8.01-55. Here, it is undisputed

that the claimants' attorney kept Hertz's attorneys apprised of

the settlement negotiations in the wrongful death suit as they

progressed. Although the commission found that the claimants'

counsel verbally accepted a settlement offer of $725,000 on

April 22, 1997, without first obtaining Hertz's approval for

that exact figure, claimants' counsel informed Hertz's attorneys

of the verbal acceptance that same day. The hearing required

under Code § 8.01-55 for formal approval of that settlement did

not occur until at least May 21, 1997, more than four weeks

later. The claimants could not execute a valid release until

after they obtained judicial approval and, thus, their actions

could not have impaired Hertz's subrogation rights prior to that

time.

During the four-week period preceding judicial

approval of the settlement, claimants' counsel provided Hertz's

counsel with a copy of the letter confirming settlement of the

third-party claim. Claimants' counsel also wrote a separate

letter, dated May 9, 1997, directly to Hertz's counsel. That

letter notified Hertz of the May 21, 1997 hearing at which the

claimants intended to seek approval of the third-party

settlement. The letter also indicated the claimants' intent

-4- thereafter to "turn [their] attention to the subrogation

interest of Hertz," indicating clearly that they did not intend

to abandon their claim for workers' compensation benefits.

Despite this notice, Hertz did not appear at the May 21, 1997

hearing and did not object to the settlement prior to the

court's entry of an order approving the settlement on May 27,

1997. Although Hertz lacked standing to oppose the court's

entry of an order approving the third-party settlement, the

claimants' or personal representative's consent remained a

prerequisite to judicial approval of the settlement. If Hertz

had communicated its objections to the claimants prior to the

hearing, entry of the court's order of approval, or the

claimants' execution of a release, the claimants could have

withdrawn their consent.

Thus, I would hold that here, as in Wood, Hertz

consented to the settlement by its inaction, and I would reverse

and remand to the commission for further proceedings consistent

with this approach, including the mandate that the commission

address the issue raised by Hertz regarding apportionment of

attorneys' fees and costs incurred by Hertz in protecting its

interests in the third-party action. Therefore, I dissent.

-5- This order shall be published and certified to the

Virginia Workers' Compensation Commission.

A Copy,

Teste:

Cynthia L. McCoy, Clerk

By:

Deputy Clerk

-6- C O R R E C T E D C O P Y

Tuesday 7th

August, 2001.

Shannon P. Skelly and Sarah E. Skelly, as Beneficiaries of Michael L. Skelly, Deceased, Appellants,

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