The Providence Mutual Fire Insurance Company v. State of Maine Department of Professional and Financial Regulation

CourtSuperior Court of Maine
DecidedMarch 22, 2016
DocketCUMap-15-034
StatusUnpublished

This text of The Providence Mutual Fire Insurance Company v. State of Maine Department of Professional and Financial Regulation (The Providence Mutual Fire Insurance Company v. State of Maine Department of Professional and Financial Regulation) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Providence Mutual Fire Insurance Company v. State of Maine Department of Professional and Financial Regulation, (Me. Super. Ct. 2016).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS. CIVIL ACTION DOCKET NO . CUMSC-AP­ 15-034

THE PROVIDENCE MUTUAL FIRE ) INSURANCE COMPANY, ) ) Petitioner, ) ) V. ) STATE OF MAINE ) Cumbeftand, ss, Clerk's Ob STATE OF MAINE DEPARTMENT ) OF PROFESSIONAL AND FINANCIAL ) MAR 22 2016 REGULATION, BUREAU OF ) INSURANCE, ) RECEIVED ) Respondent, ) ) and ) ) HARRY and KAREN KRIGMAN ) ) Parties of Interest. )

ORDER ON PETITION FOR REVIEW OF FINAL AGENCY ACTION

The Providence Mutual Fire Insurance Company ("Providence Mutual" ) has brought

this petition for review of final agency action by the Bureau of Insurance (the "Bureau" )

pursuant to the Maine Administrative Procedures Act (the "APA" ), 5 M .R.S. § 11001 et seq., and

Maine Rule of Civil Procedure SOC. Oral argument was held March 21, 2016.

Based on the following, Providence Mutual's petition for review of final agency action is

denied. The Bureau oflnsurance' s decision and order is affirmed.

I. Background

A. Undisputed Facts

In the decision and order, the superintendent of insurance made the following findings

of fact. Providence Mutual has insured five properties located in Portland, Maine owned by

Harry and Karen Krigman (the "Krigmans" ) under a businessowners policy since December

1 2008. (R. 1 ~ 1.) This appeal concerns two of the five properties: the 563 Cumberland Ave.

property and the Walton St. property. Providence Mutual inspected the 563 Cumberland Ave.

property and the Walton St. property in December 2008. (R. 1 ~ ~ 2-3. )

On August 31, 2014, a claim was submitted to Providence Mutual for injuries sustained

by claimant who fell off the front steps of the Walton Street property due to inadequate

railings . (R. 1 ~ 4.) On October 16, 2014, Providence Mutual's underwriting management

approved a renewal of the policy, effective December 5, 2014. (R. 1 ~ 5. ) The policy term was

from December 5, 2014, to December 5, 2015. (R. 1 ~ 1.) The underwriter also ordered

inspections of the 563 Cumberland Ave. and Walton St. properties, which occurred on January

26, 2015 . (R.2~6 .)

On March 11, 2015, Providence Mutual mailed the Krigmans a document titled Notice

of Cancellation, effective April 14, 2015, advising them that the 563 Cumberland Ave. and

Walton St. properties were being removed from the policy. (R. 2 ~ 7.) Providence Mutual's

stated reason was that the two properties did not meet the company's current underwriting

guidelines due to an increase in hazard resulting from inadequate maintenance and upkeep.

(Id. ) Providence Mutual stated that it would continue coverage for the other three locations

under the policy. (Id. )

B. The Administrative Proceeding

On April 27, 2015, the Krigmans requested an administrative hearing before the Bureau

of Insurance. (R. 2 ~ 8.) A hearing was held on June 23, 2015, before a designated hearing

officer pursuant to 24-A M.R.S. §§ 2908(6), 3007(6). (R. 1.) At the hearing, the Bureau

determined that Providence Mutual had the burden of establishing the existence of proof or

evidence supporting its reason fo r terminating the Krigmans' policy. (R. 1, 3.) The parties

agreed that Providence Mutual had relied on title 24-A M .R.S., section 3007(2)(C), which permits cancellation of a commercial policy for substantial changes in the risk which increase

the risk of loss after the insur ance coverage has been issued or renewed, as its basis for

cancelling · coverage. (R. 3. ) Providence Mutual's assistant vice president of underwriting

testified on behalf of the company. (R. 1.) Mr. Krigman and a contractor testified on behalf of

the Krigmans . (Id. ) Mr. Krigman and the contractor both testified that the deteriorating

conditions of the two properties had existed for some time and did not manifest after the policy

was renewed on December 5, 20 14. (R. 3.) On July 13, 20 15, the hearing officer, on behalf of

the superintendent of insurance, issued a decision and order concluding that Providence Mutual

failed to establish adequate grounds for termination and invalidated Providence Mutual's

cancellation of the Krigmans' policy. (R. 3-4. )

C. Procedural History and Issues on Appeal

On August 12, 201 5, Providence Mutual filed a petition for review of the

superintendent's decision and order pursuant to 24-A M.R.S. § 236, 5 M .R.S . § 11002(1) of the

APA, and Maine Rule of Civil Procedure SOC. Providence Mutual filed its brief on November

2, 2015. The Bureau of Insurance filed its brief on December 7, 20 15. Mr. Krigman also filed a

brief on December 7, 2015. Providence Mutual filed a reply brief on December 18, 2015 .

Providence Mutual does not contest the superintendent's findings of fact. (Br. of Pet. 1.)

Providence Mutual only contends that the superintendent's decision and order is based on

errors of law. (Id. at 6. ) Providence Mutual raises five arguments on appeal: (1 ) the

superintendent erred in its interpretation of section 3007; (2) that section 3007 did not apply to

actions taken by Providence Mutual regarding the Krigmans' policy; (3) that, under Maine law,

a renewal of an insurance policy should not constitute a waiver or estoppel with respect to

grounds for cancellation that existed before renewal; (4) the legislative history of section 3007

indicates that its primary purpose was to avoid short-term cancellations, which is an iss ue not

3 present in this case; (5) the Bureau's interpretation of section S007 (2)(C) is overly burdensome

on insurers and may impact rates and insurance availability within Maine. 1 (Id. at 7-14.)

II. Analysis

A. Standard of Review

When this court acts in its appellate capacity pursuant to Maine Rule of Civil Procedure

BOC and the APA, the court directly reviews the agency's decision for abuse of discretion, error

oflaw, or findings not supported by the evidence. Guar. Tr. Life Ins. Co. v. Superintendent ofIns.,

201S ME 102, ~ 16, 82 A.sd 121; See 5 M.R.S . § 11007(C). Generally, in a review of final

agency action, the parties must raise any objections they have before the agency in order to

preserve those issues for appeal . Forest Ecology Network v. Land Use Regulation Comm'n, 2012

ME S6, ~ 24, S9 A.sd 74. However, challenges to an administrative agency's jurisdiction or its

authority act under to its statute may be brought at any time. Sold, Inc. v. Town of Gorham,

2005 ME 24, ~ 12, 868 A.2d 172.

Statutory construction is a question of law that the court reviews de nova. Champlain

Wind, LLC v. Ed. of Envtl. Prat., 2015 ME 156, ~ 15, _ A.sd _ . The court first looks to the

plain language of the statute in or der to effectuate the Legislature's intent. Guar. Tr. Life Ins.

Co., 2013 ME 102, ~ 17, 82 A.Sd 121. In the absence oflegislative definitions, the court affords

statutory terms their plain, common, and ordinary meaning. Dickau v. Vt. Mut. Ins. Co., 2014

ME 158, ~ 22, 107 A.sd 621. The court rejects statutory interpretations that render some

1 Providence Mutual's brief actually addresses both 24-A M.R.S. § 2908 and 24-A M.R.S. § 3007 . (Br. of Pet. 7-14.) However, this court's analysis is confined to section 3007 .

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