TATUM v. PROGRESSIVE INSURANCE CO.

CourtDistrict Court, E.D. Pennsylvania
DecidedJune 23, 2025
Docket2:24-cv-02086
StatusUnknown

This text of TATUM v. PROGRESSIVE INSURANCE CO. (TATUM v. PROGRESSIVE INSURANCE CO.) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TATUM v. PROGRESSIVE INSURANCE CO., (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

JULIE TATUM and VINCE BRACCILI, : CIVIL DIVISION : Plaintiffs, : : v. : : PROGRESSIVE SPECIALTY : INSURANCE COMPANY, : : Defendant. : NO. 24-2086

MEMORANDUM KENNEY, J. June 23, 2025 Plaintiffs Julie Tatum (“Ms. Tatum”) and Vince Braccili (“Mr. Braccili”) (together, “Plaintiffs”) filed a nine-count Complaint against Progressive Specialty Insurance Company (“Progressive” or “Defendant”) and one of its adjusters. ECF No. 1 at 171. The Court dismissed the adjuster as a defendant, ECF No. 14, and dismissed all but three counts against the Defendant: Count I (Bad Faith Pursuant to 42 Pa. C.S.A. §8371 (“Section 8371”)), Count II (Breach of Contract/Good Faith and Fair Dealing), and Count IX (Loss of Consortium). ECF Nos. 18, 19, 25. Before the Court is Defendant’s Motion for Summary Judgment (ECF No. 56, “Motion”) on the remaining counts along with its accompanying Brief in Support of the Motion for Summary Judgment (ECF No. 57) and Stipulated Concise Statement of Undisputed Material Facts (ECF No. 58, “SOF”). Plaintiffs filed their Response to the Motion (ECF No. 59), to which Defendant filed its Reply (ECF No. 61), followed by a Sur-Reply by the Plaintiffs (ECF No. 62).1 The Motion is now ripe for consideration.

For the reasons discussed below, the Motion is GRANTED. I. FACTUAL AND PROCEDURAL BACKGROUND2 Ms. Tatum was involved in a motor vehicle accident on June 11, 2021. SOF ¶ 1. At the time of her accident, she was insured under an automobile insurance policy by Defendant (the “Policy”). Id. ¶ 2. The Policy provided up to $15,000 in underinsured motorist (“UIM”) coverage,

subject to the terms and conditions of the policy. Id. ¶ 3. Progressive agreed to reform the policy to provide stacked coverage up to $45,000. Id. ¶ 4. Ms. Tatum elected limited tort coverage. Id. ¶ 5. Since the other driver involved in the accident had $15,000 in liability insurance coverage, Ms. Tatum was not entitled to UIM benefits unless her damage exceeded $15,000. Id. ¶¶ 7–8. a. Progressive Opens and Evaluates Ms. Tatum’s UIM Claim On June 21, 2021, Progressive was made aware that Ms. Tatum hired legal counsel to represent her for injuries she sustained in the accident, id. ¶ 9, but she did not make a formal claim

for UIM benefits before suing for those benefits in April of 2022, id. ¶ 10. On April 21, 2022, Progressive opened a UIM claim on Ms. Tatum’s behalf that was assigned to Thomas Murray (“Murray”). Id. ¶¶ 11–12. Murray noted that there was no dispute the policy provided $45,000 in UIM coverage such that the focus of the investigation would be damages. Id. ¶¶ 13–14. Since the other driver had $15,000 in coverage, Ms. Tatum’s damages would have to exceed that amount to recover UIM benefits. Id. ¶ 15. At the time of Murray’s initial review, he had been provided no

1 The Sur-Reply (ECF No. 62) is not responsive to the Reply (ECF No. 61) although it is signed and dated correctly on the Certificate of Service. 2 The SOF uses “Plaintiff” and “Plaintiffs” interchangeably. See, e.g., SOF ¶¶ 16–17. The Court will refer to “Ms. Tatum” when it is clear the SOF only means her individually and “Plaintiffs” when it clearly is referring to all Plaintiffs. documentation of Ms. Tatum’s injuries. Id. ¶ 16. Murray noted he would obtain medical records, work with counsel to schedule a deposition, and evaluate Ms. Tatum’s claim. Id. ¶ 17.

Plaintiffs’ counsel sent a demand package to Murray on May 5, 2022, which he reviewed shortly thereafter. Id. ¶¶ 18–19. After conducting his initial evaluation and noting he needed more information, Murray noted Ms. Tatum had sustained a concussion for which she had been treated and discharged after making a 100% recovery. Id. ¶ 21. He also noted that an MRI showed a disc protrusion.3 Id. ¶ 22. Murray noted that there were no references to prior concussions or back issues in Ms. Tatum’s medical records. Id. ¶ 23. Murray did not assign any value to the disc protrusion at the time of his initial review

because “we’ll need to get film reviewed to get an opinion on causation.” Id. ¶¶ 24–25; see also id. ¶ 26. Murray then contacted Plaintiffs’ counsel to request information regarding out-of-pocket medical expenses or lost wages as well as information regarding scars and disfigurements resulting from airbag burns. Id. ¶¶ 27–28. Ms. Tatum’s counsel confirmed on May 18, 2022, that Ms. Tatum did not have health insurance at the time and that lost wage information would be provided. Id. ¶¶ 29–30. On June 15, 2022, Plaintiffs’ counsel emailed Murray pictures of Ms. Tatum’s air bag injuries and stated that they were still awaiting wage loss verification. Id. ¶ 32. Beginning July 14, 2022, Murray reached out to Plaintiffs’ counsel by email and phone requesting wage loss information on four occasions until Plaintiffs’ counsel finally informed Murray that the wage loss claims were being dropped on February 3, 2023. Id. ¶¶ 32–40.

Upon learning Ms. Tatum would not be presenting a wage loss claim, Murray evaluated her claim and performed a second UIM evaluation on March 2, 2023. Id. ¶¶ 41–42. Murray noted

3 The SOF and exhibits regularly use “disc protrusion” and “disc herniation” interchangeably. Compare ECF No. 58 ¶ 22, with id. ¶ 74; compare ECF No. 58-4 at 37, with id. at 68; compare ECF No. 58-5 at 3, with id. at 4. The Court will use the term used in the specifically cited portion of the document. that general damages were between $17,000 and $24,000, Ms. Tatum had out of pocket medical expenses totaling $1,027, and she underwent conservative treatments that included one trigger point injection for approximately four months. Id. ¶¶ 43–45. Murray noted a question regarding whether the limited tort threshold would be pierced. Id. ¶ 46. At that time, Murray noted that an

MRI showed a disc protrusion but did not assign any value to the protrusion. Id. ¶¶ 47–48. Murray again noted that “we’ll need to get film reviewed to get an opinion on causation.” Id. ¶ 49. b. Plaintiff’s Deposition and the Expert Reports Ms. Tatum’s deposition was scheduled for March 7, 2023, and Murray and his supervisor decided to wait to finalize the evaluation until after the deposition to further assess the limited tort issue. Id. ¶ 50. Murray attended the deposition, took detailed notes, and completed a post- deposition call with his supervisor and defense counsel. Id. ¶¶ 51, 53. After the deposition, Murray concluded that it did not appear that Ms. Tatum’s injuries would breach the limited tort threshold.

Id. ¶ 54. On April 24, 2023, Ms. Tatum produced the expert report of her treating physician, Dr. Murphy, a physical therapist. 4 Id. ¶¶ 55–59. After Ms. Tatum’s last treatment by Dr. Murphy in October of 2021, he discharged Ms. Tatum from physical therapy to a home exercise program. Id. ¶ 60. In his report, Dr. Murphy opined that the prognosis for the recovery of Ms. Tatum’s disc protrusion was poor without surgical intervention and that she would require either ongoing physical therapy/injections into the future and/or surgical interventions if she has unremitting pain.

Id. ¶¶ 61–62. Dr. Murphy opined that the protrusion was related to the accident. Id. ¶ 63. Dr. Murphy was the only doctor who asserted Ms. Tatum would need physical therapy or surgery in the future. Id. ¶ 64. Ms. Tatum has not received any physical therapy from Dr. Murphy since she

4 Dr. Murphy’s signature block includes the title “DO.” See ECF No. 58-7 at 7. was discharged in October of 2021. Id. ¶ 65. Murray did not interpret Dr. Murphy’s October 19, 2021 office note, which states, “we discussed treatment options today again, both invasive and noninvasive,” to mean potential future surgery. Id. ¶ 81.

In April 2023, Murray requested that Dr. Lee Harris, a neurologist, review Ms.

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