State Farm Insurance Co. v. Azar

2019 IL App (1st) 190575-U
CourtAppellate Court of Illinois
DecidedNovember 12, 2019
Docket1-19-0575
StatusUnpublished

This text of 2019 IL App (1st) 190575-U (State Farm Insurance Co. v. Azar) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Farm Insurance Co. v. Azar, 2019 IL App (1st) 190575-U (Ill. Ct. App. 2019).

Opinion

2019 IL App (1st) 190575-U No. 1-19-0575 Order filed November 12, 2019 First Division NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(c)(2). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ ) STATE FARM MUTUAL INSURANCE COMPANY, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. v. ) ) No. 17 CH 12822 ADEL AZAR, ) ) Honorable Defendant-Appellant. ) Sophia H. Hall, ) Judge, presiding.

JUSTICE HYMAN delivered the judgment of the court. Presiding Justice Griffin and Justice Pierce concurred in the judgment.

ORDER

¶1 Held: Trial court did not err in requiring defendant to prove he made a timely demand for arbitration under insurance policy’s uninsured motorist provision.

¶2 The car in which Adel Azar was a passenger got in an accident with an uninsured

motorist. Azar pursued a claim against State Farm Mutual Automobile Company, the car’s

insurer. State Farm filed a complaint seeking a declaration of no coverage. State Farm asserted

Azar brought the claim untimely under the policy’s uninsured motorist provision having waited

more than two years to make a demand for arbitration. After a bench trial, the trial court declared No. 1-19-0575

Azar’s uninsured motorist claim to be time barred and entered a judgment in State Farm’s favor.

Azar contends the trial court erred in requiring him to prove he made a timely demand for

arbitration and improperly shifted the burden to him regarding the presumption of mailing. The

trial court properly placed the burden on Azar as the claimant, so we affirm.

¶3 Background

¶4 Azar was the passenger in a car driven by Assi Sayegh when an accident occurred with

an uninsured motorist on September 30, 2014. Azar sought to file a claim under the uninsured

motorist provision of Sayegh’s insurance policy issued by State Farm. The policy’s uninsured

motorist provision provided, in relevant part, “Any arbitration or suit against us will be barred

unless commenced within two years after the date of the accident or within two years

immediately following the date the carrier for the uninsured motor vehicle becomes insolvent, if

the carrier becomes insolvent within two years immediately following the date of the accident.

Legal action may only be brought against us in accordance with the Legal Action Against Us

provision of this policy.”

¶5 Almost three years after the accident, on September 17, 2017, State Farm filed a

complaint seeking a declaration that Azar’s claim was time barred. State Farm argued Azar

exceeded the policy’s two year time limit to file a suit or demand arbitration of his uninsured

motorist claim. State Farm alleged that shortly after the accident, it received an attorney

representation letter and an attorney lien letter from Azar’s attorneys, The Vrdolyak Law Group.

State Farm received no additional correspondence until July 17, 2017, when his attorney sent a

letter demanding arbitration of the claim. Because that letter was more than two years after the

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accident, State Farm asked the trial court to find Azar’s claim time-barred, and that State Farm

had no obligation to arbitrate.

¶6 After Azar filed a response to the complaint denying that he failed to timely demand

arbitration of his uninsured motorist claim, State Farm moved for summary judgment under

section 2-1005 of the Code of Civil Procedure (735 ILCS 5/2-1005 (West 2016)), again arguing

Azar did not commence arbitration or file suit against within two years of the accident as

required by the policy. In response, Azar argued he complied with the policy by sending two

letters demanding arbitration on April 13, 2016, less than two years after the accident. Azar

provided copies of the letters, which were properly addressed to State Farm. Azar also provided

an affidavit and discovery deposition from James Pineda, a case manager for Azar’s attorney,

stating that at the attorney’s direction, he sent the April 2016 letters to State Farm. (It was the

firm’s practice to send two letters, one demanding ADR Systems as arbitrator because it was a

quicker and less expensive option, and the other naming a specific arbitrator.) The trial court

denied the summary judgment motion, finding that the letters created a question of fact as to

whether Azar made a timely demand for uninsured motorist arbitration.

¶7 At the beginning of the trial, the trial court informed the parties that Azar had the burden

of proving he made a timely demand for arbitration. Azar presented three witnesses: case

manager James Pineda and attorneys Peter Vrdolyak and John Vrdolyak. Pineda’s duties

included assisting Peter Vrdolyak in uninsured motorist claims. He testified it was his custom

and practice to draft arbitration demand letters using a template, sign and initial the letters, make

copies, put them in regular first class mail, and place the copy in the case file. He said he

followed this custom and practice when he sent two arbitration demand letters to State Farm in

Azar’s case on April 13, 2016. He acknowledged that he sent hundreds if not thousands of

-3- No. 1-19-0575

similar letters on behalf of other clients, but had specific recall of printing and mailing those two

letters. On cross-examination, he acknowledged he could not remember anything else about

other files he worked on that day.

¶8 Peter Vrdolyak testified he handles pre-litigation matters, and it was his custom and

practice to have Pineda send correspondence to insurers, including letters demanding arbitration

for uninsured motorist claims. He directed Pineda to send the two letters to State Farm

demanding arbitration of Azar’s claim. But, on cross-examination, he acknowledged he did not

have any independent recollection of the Azar case or of instructing Pineda to send the April 13,

2016 letters to State Farm.

¶9 John Vrdolyak testified that he handled Azar’s case once it reached the litigation stage.

He was not involved in drafting or sending the April 13, 2016 letters. He had no independent

recollection of the letters being in the case file, but presumed they were there. He said he sent the

July 17, 2017 arbitration demand letter because there were no responses from State Farm in the

file regarding prior arbitration demands.

¶ 10 State Farm called claims specialist Cathleen McDermott. McDermott worked on the Azar

claim after the two years to demand arbitration had expired. She reviewed the file and did not

find an arbitration demand letter, so she recommended closing the file. The only arbitration

demand letter in Azar’s claim file was the July 17, 2017 letter. McDermott acknowledged that

the April 13, 2016 letters were not sent to her but testified that all correspondence on a claim

ends up in the electronic claim file regardless of which office originally receives it.

¶ 11 After hearing the evidence and closing arguments, the trial court found in favor of State

Farm and against Azar. The court said the case turned on James Pineda’s credibility and found

-4- No. 1-19-0575

his testimony “incredible.” The court stated, “I cannot believe he remembered this particular

document.

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Cite This Page — Counsel Stack

Bluebook (online)
2019 IL App (1st) 190575-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-farm-insurance-co-v-azar-illappct-2019.