Spilled Milk v. Nautilus Insurance Company

CourtSuperior Court of Pennsylvania
DecidedOctober 28, 2025
Docket240 EDA 2024
StatusUnpublished

This text of Spilled Milk v. Nautilus Insurance Company (Spilled Milk v. Nautilus Insurance Company) 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
Spilled Milk v. Nautilus Insurance Company, (Pa. Ct. App. 2025).

Opinion

J-A01041-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

SPILLED MILK, INC. D/B/A : IN THE SUPERIOR COURT OF PHILLYRUBBER.COM : PENNSYLVANIA : Appellant : : : v. : : : No. 240 EDA 2024 NAUTILUS INSURANCE COMPANY, : MICHAEL R. SHELLY, ZENITH PUBLIC : ADJUSTERS, LLC, AND LIBERTY : PUBLIC ADJUSTERS, LLC :

Appeal from the Order Entered December 11, 2023 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 220601343

BEFORE: DUBOW, J., KING, J., and SULLIVAN, J.

MEMORANDUM BY SULLIVAN, J.: FILED OCTOBER 28, 2025

Spilled Milk, Inc. d/b/a PhillyRubber.com (“Spilled Milk”), the plaintiff

below, appeals from the final judgment entered after the trial court, in

relevant part, sustained the preliminary objections in the nature of demurrer

filed by one of the defendants, Nautilus Insurance Company (“Nautilus”), and

assessed damages against the remaining defendants. Because the trial court

misapplied the standard of review when deciding Nautilus’s preliminary

objections, we vacate the judgment in part, reverse the dismissal of the

Spilled Milk’s claims against Nautilus, and remand this matter for further

proceedings.

We summarize the factual background relevant to this appeal based

upon the facts alleged in Spilled Milk’s amended complaint. Spilled Milk J-A01041-25

manufactures rubber products and had a commercial insurance policy with

Nautilus (the “policy”). See Spilled Milk’s Am. Compl., 8/16/22, at ¶¶ 2, 25.

Spilled Milk suffered a loss at a factory in Philadelphia and retained Zenith

Public Adjusters, LLC (“Zenith”) to advise and assist in the adjustment of an

insurance claim with Nautilus. See id. at ¶¶ 4, 54-58. An employee of Spilled

Milk signed a letter of representation under Zenith’s letterhead, which Nautilus

received, and which read:

This is to certify that Zenith . . . is hereby retained to advise and assist in the adjustment of the insurance claim arising from [the] loss . . ..

I/we request that all correspondence relating to this loss be directed solely to Zenith . . ..

Please include the name Zenith . . . on all drafts or checks pertaining to th[e] loss and please forward all of the same to Zenith . . . at the above address [in Newtown Square].

See id., Ex. 2 (hereinafter cited as “Ltr. of Representation, 1/23/19”).

Michael R. Shelly (“Shelly”) was an officer with Zenith, but he also

controlled an entity referred to as Liberty Public Adjusters, LLC (“Liberty”).

See id. at ¶¶ 9, 31-32. Shelly settled Spilled Milk’s insurance claim with

Nautilus, and he instructed Nautilus to pay Liberty. See id. at ¶¶ 9, 70-72.

Nautilus issued a total of $722,468.41 in checks (“the proceeds”) to Liberty,

and at least two of those checks named Spilled Milk and Liberty as joint

-2- J-A01041-25

payees. See id. at ¶¶ 13; see also id., Ex. 5.1 Neither Nautilus nor Shelly

informed Spilled Milk of the settlement or the payments of the proceeds, and

Shelly thereafter stole the proceeds. See id. at ¶¶ 12, 14-15. When Spilled

Milk learned of the settlement and payments to Liberty, Spilled Milk demanded

Nautilus pay Spilled Milk directly for its insurance claim. See id. at ¶ 16.

Spilled Milk’s and Nautilus’s attorneys exchanged a letter denying Spilled

Milk’s demand, a letter in response to the denial, and a letter in reply to the

response. See id. at ¶¶ 89-106; see also id., Exs. 5-7. In explaining the

denial of Spilled Milk’s demand, Nautilus’s counsel indicated Nautilus would

not reissue checks to replace the proceeds stolen by Spilled Milk’s agent. See

id., Ex. 7, at 2.2

Spilled Milk commenced the underlying action against Nautilus, Shelly,

Zenith, and Liberty. As set forth in its amended complaint, Spilled Milk

____________________________________________

1 The amended complaint included copies of two checks. See Spilled Milk’s Am. Compl., 8/16/22, Ex. 5. Those checks indicate Nautilus paid $672,486.41 of the proceeds to the order of “Spilled Milk Inc. dba PhillyRubber.com & Liberty Public Adjusters LLC.” See id. (some capitalization omitted) The backs of those checks include handwritten endorsement by Spilled Milk and “Liberty Public Adjusters dba Zenith Public Adjusters.” See id. (some capitalizations omitted). There is no indication Spilled Milk endorsed those checks.

2 The amended complaint referred to a consent order between the Insurance

Department of Pennsylvania and Shelly and Zenith which found Shelly and Zenith failed to remit $722,486.41 to Spilled Milk, as well as Shelly’s conviction for criminal offenses. See id. at ¶¶ 83-85. Although the consent order was not attached to the amended complaint, it was later added to the record as an exhibit. The consent order did not mention Liberty, and the record contains no further clarification on what, if any, corporate relationship there had been between Zenith and Liberty.

-3- J-A01041-25

asserted Nautilus made unauthorized payments to an improper party, i.e.,

Liberty, and failed to inform or consult with Spilled Milk before so doing. See

id. at ¶¶ 10-13. For those reasons, Spilled Milk suggested that Nautilus had

yet to properly pay for Spilled Milk’s insurance claim. In count I of the

amended complaint, Spilled Milk claimed that Nautilus’s improper payment to

Liberty and refusal to pay Spilled Milk’s subsequent demand constituted

breaches of the insurance policy and Nautilus’s duty of good faith and fair

dealing. See id. at ¶¶ 114-25. In count II, Spilled Milk claimed Nautilus’s

refusals of Spilled Milk’s demands constituted a bad faith in violation of 42

Pa.C.S.A. § 8371. See id. at ¶¶ 132-35.3 In count III, Spilled Milk raised an

alternative claim that Nautilus was unjustly enriched by keeping Spilled Milk’s

premiums without making a proper payment to Spilled Milk. See id. at ¶¶

137-40.

3 Section 8371 states:

In an action arising under an insurance policy, if the court finds that the insurer has acted in bad faith toward the insured, the court may take all of the following actions:

(1) Award interest on the amount of the claim from the date the claim was made by the insured in an amount equal to the prime rate of interest plus 3%.

(2) Award punitive damages against the insurer.

(3) Assess court costs and attorney fees against the insurer.

42 Pa.C.S.A. § 8371.

-4- J-A01041-25

Nautilus filed preliminary objections and, in relevant part, challenged

the legal sufficiency of the three counts against it. Nautilus maintained that

it properly paid for Spilled Milk’s loss “as directed by [Spilled Milk’s] authorized

agent, Zenith.” Nautilus’s Prelim. Objs. to Am. Compl., 9/6/22, at ¶ 30.

Nautilus noted that it included Spilled Milk as a joint payee on checks it issued,

which would have required Shelly to forge Spilled Milk’s endorsements. See

id. at ¶¶ 31-32. Nautilus further claimed that it had no duty to communicate

with Spilled Milk about the request to pay Liberty because the letter of

representation had instructed Nautilus to direct all correspondence related to

the loss solely to Zenith. See id. at ¶¶ 26-27. Nautilus concluded that Spilled

Milk’s allegations against it for breach of contract (count I) were legally

insufficient because the amended complaint established only that Spilled Milk

was a victim of the criminal actions of Spilled Milk’s own agent. See id. at ¶¶

28-30 (citing Rothman v. Fillette,

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