Skyward Specialty Insurance Group Inc v. Precision Risk Management Inc

CourtDistrict Court, W.D. Washington
DecidedJanuary 25, 2023
Docket3:21-cv-05553
StatusUnknown

This text of Skyward Specialty Insurance Group Inc v. Precision Risk Management Inc (Skyward Specialty Insurance Group Inc v. Precision Risk Management Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Skyward Specialty Insurance Group Inc v. Precision Risk Management Inc, (W.D. Wash. 2023).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 SKYWARD SPECIALTY CASE NO. C21-5553 BHS 8 INSURANCE GROUP, INC., ORDER 9 Plaintiff, v. 10 DYNAN & ASSOCIATES, P.S., 11 Defendant. 12

13 THIS MATTER is before the Court on Plaintiff Skyward Specialty Insurance 14 Group and Defendant Dynan & Associates’ Motion for an Order Approving Settlement 15 and Barring Claims, Dkt. 24. Because the proposed settlement is reasonable and because 16 the rights of the non-settling entity, Precision Risk Management, are protected, the 17 motion is GRANTED. 18 I. BACKGROUND 19 In 2004, Skyward’s predecessor, Sirius,1 issued a property insurance policy to the 20 Northgate Plaza Condominium Homeowners Association. Dkt. 1 at 5. In March 2019, 21

22 1 This Order will refer to all the insurers as “Skyward” for clarity. 1 Northgate discovered long-term water damage at its property. Id. In August 2019, 2 Northgate submitted a $4.8 million claim to Skyward.2 Skyward assigned its contracted 3 claims administrator, defendant Precision Risk Management (“PRM”) to investigate the

4 claim, consistent with its pre-existing “claims management agreement” with PRM. Id. at 5 6; see also Dkt. 13-1. PRM investigated the claim and obtained coverage counsel, Mark 6 Dynan, to opine on whether the claim was covered under Skyward’s policy. Dkt. 1 at 6. 7 Skyward alleges that PRM investigated the claim and that in January 2020, Dynan 8 authored a letter denying Northgate’s claim on Skyward’s behalf. Id. Skyward asserts that

9 Dynan relied on PRM’s investigation and that his letter denied the claim based on 10 improper repairs, long term damage, and faulty workmanship/design. Id. 11 In March 2020, Northgate sent Dynan and Skyward an Insurance Fair Conduct 12 Act (“IFCA”) notice, alleging that Skyward had failed to adequately investigate its claim 13 and wrongfully denied it under the Skyward policy. Northgate sued in April 2020. See

14 Northgate Plaza Homeowners Ass’n v. Sirius Am. Ins. Co., No. 20-cv-0519 DWC. 15 Northgate alleged that Skyward unreasonably denied its claim “without conducting an 16 intrusive investigation of the hidden damage at the Northgate Plaza Condominium.” See 17 id., Dkt. 1 at 4. 18 //

19 // 20

21 2 It is not clear and perhaps not important whether Northgate sought coverage or indemnity under any other property insurance policy. Skyward apparently insured the property 22 for a single year—2004. 1 Skyward ultimately paid Northgate $500,000 to settle its claims at mediation. 2 Skyward now asserts that its payment included a premium to avoid Northgate’s potential 3 bad faith claim against it based on PRM’s investigation and Dynan’s coverage opinion.

4 In August 2021, Skyward sued PRM for breach contract, including its failure to 5 provide a timely and adequate investigation of Northgate’s claim. It sought 6 indemnification for the payment to Northgate based on PRM’s claim handling. Dkt. 1 at 7 7. Skyward also sued Dynan for legal malpractice, based on his allegedly negligent 8 coverage opinion and his coverage denial letter. Skyward alleges that Dynan’s negligence

9 caused it to pay Northgate an amount “in excess of any indemnity amount covered by the 10 policy.” Id. at 9. 11 PRM moved to dismiss for improper venue and to compel arbitration under the 12 Skyward/PRM claims management agreement. Dkt. 12. The Court granted that motion, 13 Dkt. 19, leaving in this case only Skyward’s legal malpractice claim against Dynan.

14 Skyward and Dynan have now settled, conditioned on the Court’s approval of 15 their confidential settlement as reasonable, and the entry of an RCW Ch. 4.22 claim bar 16 order, precluding PRM from seeking to recover from Dynan any sums it may be required 17 to pay Skyward, if Skyward successfully pursues its claims against PRM in New York. 18 //

19 // 20 // 21 // 22 // 1 II. DISCUSSION 2 The parties argue that their settlement is the result of arms-length negotiations, 3 that it is objectively reasonable, and that the non-settling party’s3 (PRM’s) interests are

4 protected. Dkt. 24 at 4–7. The settling parties jointly assert that, because they have agreed 5 that Skyward will credit the funds paid by Dynan against any damages recoverable from 6 other entities not party to their settlement agreement (PRM), the agreement cannot 7 operate to increase any of PRM’s obligations to Skyward, and that it therefore adequately 8 protects PRM’s interests. Id. at 3 (citing Dkts. 25 and 27). They assert their settlement

9 and the bar order they seek protects PRM because they will not seek from PRM any 10 amounts that PRM could have recovered from Dynan. Dkt. 24 at 7. 11 PRM does not oppose the settlement and concedes that it is reasonable. Dkt. 29 at 12 1. PRM does object to the settling parties’ proposed bar order, holding that “any claims 13 for contribution, allocation, subrogation, and equitable indemnity and any other cause of

14 action in connection with this action against Dynan are hereby BARRED.” Dkt. 29 at 2. 15 PRM argues primarily that an Order barring contribution claims under 16 Washington’s “fault” statute, RCW Ch. 4.22, relates (only) to tort liability and cannot 17 affect any contractual indemnity claims PRM has against Dynan, if PRM is forced to pay 18 Skyward “the rest” of its damage claim arising from Northgate’s claim and Skyward’s

19 $500,000 payment to settle it. 20

21 3 PRM is no longer a “party,” because it elected to invoke its contractual right to have the case arbitrated in New York, under New York law. The remaining parties provided PRM notice 22 of this motion and an opportunity to object to it. 1 PRM also argues that Skyward’s calculation of its exposure to Northgate under its 2 policy—a fraction of Northgate’s claim, based on its “time on the risk”—is not supported 3 by Washington law. Dkt. 29 at 4 n.1. Indeed, it describes Skyward’s entire liability theory

4 against it (and Dynan) as a “non-sequitur.” Id. at 3. 5 Dynan asserts, and the Court agrees, that it must evaluate the settlement’s 6 reasonableness and the parties’ request for a bar order under the so-called Glover factors: 7 1. Skyward’s damages; 8 2. the merits of Skyward’s liability theory;

9 3. the merits of Dynan’s defense theory; 10 4. Dynan’s relative fault; 11 5. the risks and expenses of continued litigation; 12 6. Dynan’s ability to pay; 13 7. any evidence of bad faith, collusion, or fraud;

14 8. the extent of Skyward’s investigation and preparation of the case; and 15 9. PRM’s interests. 16 Dkt. 31 at 2 (citing Glover v. Tacoma Gen. Hosp., 98 Wn. 2d 708, 717 (1983) (modified 17 to identify the players in this case)). Dynan asserts that PRM’s objections are challenges 18 to the settlement under the second (liability theory) and ninth (non-settling party’s

19 interest) Glover factors. Dkt. 31 at 3–4. 20 PRM’s criticism of Skyward’s liability theory facially makes sense. It asserts that, 21 if Dynan’s coverage advice to Skyward was correct—that Northgate’s underlying 22 insurance claim was not covered by Skyward’s policy—then neither Dynan nor PRM 1 could be liable for providing that advice. If the advice was wrong, and the underlying 2 claim was covered, then Skyward was contractually obligated to pay its insured for its 3 loss; neither Dynan’s advice nor PRM’s inadequate investigation caused Skyward to be

4 liable to Northgate under its insurance contract. Dkt. 29 at 3. 5 Skyward responds that its settlement payment was primarily to resolve its 6 exposure to Northgate’s potential4 bad faith claim (based on the wrongful denial of its 7 claim, based on PRM’s inadequate investigation and Dynan’s erroneous advice). It 8 asserts that its contractual exposure on Northgate’s claim was based on its “time on the

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Skyward Specialty Insurance Group Inc v. Precision Risk Management Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/skyward-specialty-insurance-group-inc-v-precision-risk-management-inc-wawd-2023.