Tina MacKay V. PEMCO Mutual Insurance Company

CourtCourt of Appeals of Washington
DecidedJuly 30, 2024
Docket39625-8
StatusUnpublished

This text of Tina MacKay V. PEMCO Mutual Insurance Company (Tina MacKay V. PEMCO Mutual Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tina MacKay V. PEMCO Mutual Insurance Company, (Wash. Ct. App. 2024).

Opinion

FILED JULY 30, 2024 In the Office of the Clerk of Court WA State Court of Appeals Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

TINA MACKAY, a single woman, ) ) No. 39625-8-III Appellant, ) ) v. ) ) PEMCO MUTUAL INSURANCE ) UNPUBLISHED OPINION COMPANY, a Washington Insurance ) Company, ) ) Respondent. )

COONEY, J. ⎯ Shortly after purchasing a homeowner’s insurance policy (Policy)

from PEMCO Mutual Insurance Company (PEMCO), a fire ravaged Tina MacKay’s

home. Ms. MacKay made a claim under the Policy that was promptly accepted by

PEMCO. A dispute then arose over how sales tax on Ms. MacKay’s personal property

was calculated. PEMCO used the actual cash value of the damaged property to calculate

sales tax while Ms. MacKay asserted that sales tax ought to be calculated on the

replacement cost.

Ms. MacKay filed suit against PEMCO asserting claims for breach of contract,

violation of Washington’s Insurance Fair Conduct Act, ch. 48.30.010-.015 RCW,

violation of the Consumer Protection Act, ch. 19.86 RCW, bad faith, unjust enrichment, No. 39625-8-III MacKay v. Pemco Mut. Ins. Co.

and declaratory judgment. Thereafter, PEMCO filed a motion for summary judgment,

seeking dismissal of Ms. MacKay’s claims. The trial court granted PEMCO’s motion.

On appeal, we are presented with three questions. First, because the Policy does

not define sales tax or explain how sales tax is treated for depreciation purposes, is the

Policy’s definition of “actual cash value” ambiguous? Secondly, can the Policy be

reasonably interpreted to include sales tax on the replacement cost of damaged property

when reimbursing the actual cash value of that property? Thirdly, does a Washington

State insurance commissioner rule that prohibits the depreciation of the expense of labor

impliedly preclude the depreciation of sales tax?

We conclude the Policy’s definition of “actual cash value” is not susceptible to

more than one reasonable interpretation, that the Policy cannot reasonably be interpreted

to include sales tax on the replacement cost of damaged property when calculating the

actual cash value, and decline to apply the insurance commissioner’s rule prohibiting the

depreciation of the expense of labor. Accordingly, we affirm the trial court’s order on

summary judgment.

BACKGROUND

In June 2017, Ms. MacKay purchased a homeowner’s insurance policy from

PEMCO. Under “Coverage C − Personal Property” of the Policy, Ms. MacKay was

2 No. 39625-8-III MacKay v. Pemco Mut. Ins. Co.

allowed to recover the replacement cost for any property loss up to $174,300. Clerk’s

Papers (CP) at 118, 131. In part, the Policy defined “replacement cost” as:

b. In case of loss to personal property, replacement cost means the cost, at the time of loss, of a new article identical to the one damaged, destroyed or stolen. When the identical article is no longer manufactured or available, replacement cost means the cost of a new article similar to the one damaged or destroyed and which is of comparable quality and usefulness, without deduction for depreciation.

CP at 123-24.

Later, the Policy was modified by Homeowners Amendatory Endorsement PM 49.

Under Endorsement PM 49, coverage C was amended to include the following provision:

3. d. When the replacement cost of the entire loss is more than $1,500, [PEMCO] will pay no more than the actual cash value for the loss or damage until the actual repair or replacement is complete, and then no more than the amount actually and necessarily spent to repair or replace.

CP at 145. The Policy defined “actual cash value” as:

1. Actual Cash Value means: .... b. When the loss or damage to the property creates a total loss, actual cash value means the market value of property in a used condition equal to that of the destroyed property, if reasonably available on the used market. c. Otherwise, actual cash value means the market value of new, identical or nearly identical property less reasonable deduction for wear and tear, deterioration and obsolescence.

CP at 123.

3 No. 39625-8-III MacKay v. Pemco Mut. Ins. Co.

In the event an insured suffered loss or damage of their property, the Policy

provided a two-step process for indemnification. First, for purposes of making an initial

actual cash value payment to the insured, PEMCO calculated the actual cash value of the

damaged property. The actual cash value was determined by assessing the market value

of the property, less a deduction for depreciation, then applying the sales tax rate

effective in the insured’s zip code. Secondly, if the insured replaced the damaged

property, PEMCO would reimburse the difference between the actual cash value of the

damaged property and the replacement cost paid by the insured, including sales tax. If an

insured chose against replacing a damaged item, the Policy provided that PEMCO would

only reimburse the actual cash value of the property.

On April 15, 2018, a fire at Ms. MacKay’s home damaged her personal property.

Ms. MacKay promptly notified PEMCO of the loss. PEMCO determined the loss was

covered by the Policy and issued Ms. MacKay a $5,000 advanced actual cash value

payment. Loree Eads, a content inventory specialist with PEMCO, began cataloging the

damaged property. Ms. Eads’ inventory list included, among other information, the

actual cash value of the damaged property, the replacement value of the damaged

property, and whether the damaged items were subject to sales tax. When Ms. MacKay

replaced an item, Ms. Eads would determine the replacement payment due Ms. MacKay.

The replacement payment was the difference between the actual cash value of the

4 No. 39625-8-III MacKay v. Pemco Mut. Ins. Co.

damaged item and the cost Ms. MacKay actually paid for the new item, including sales

tax on the purchase price.

In her first report, Ms. Eads estimated the replacement cost due Ms. MacKay was

$26,063.22. After applying the applicable sales tax of 8.2 percent, totaling $2,137.18,

Ms. Eads calculated a total replacement cost of $28,200.40. To assess the actual cash

value, Ms. Eads reduced the replacement cost by applying a depreciation to the damaged

property. Ms. Eads calculated the actual cash value of the damaged property at

$18,948.18. Ms. Eads then added the applicable sales tax rate for a total estimated actual

cash value of $20,501.93.

PEMCO made an initial actual cash value payment to Ms. MacKay of $15,501.93.

This amount consisted of the actual cash value of the damaged property, $20,501.93, less

the $5,000 advanced actual cash value payment. Ms. Eads identified other damaged

property not included in the initial actual cash value report. This led to PEMCO issuing a

second actual cash value payment to Ms. MacKay of $50,976.18. In 2019, after

additional damaged property was identified by Ms. Eads, a third actual cash value

payment of $19,074.62 was issued to Ms. MacKay.

On May 17, 2019, Ms. MacKay’s home was restored, allowing for her return.

PEMCO paid Ms. MacKay $11,774.15 to pack, clean, store, and deliver her personal

property from her temporary place of residence to her home. Following these payments,

5 No. 39625-8-III MacKay v. Pemco Mut. Ins. Co.

PEMCO attempted to contact Ms. MacKay to inquire whether she intended to submit

additional claims under coverage C. PEMCO never received a response.

In June 2020, Ms. MacKay filed a lawsuit against PEMCO that alleged PEMCO

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Tina MacKay V. PEMCO Mutual Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tina-mackay-v-pemco-mutual-insurance-company-washctapp-2024.