TNT Gaming Center LLC v. American Specialty Insurance & Risk Services Inc

CourtDistrict Court, N.D. Texas
DecidedDecember 10, 2024
Docket3:24-cv-01995
StatusUnknown

This text of TNT Gaming Center LLC v. American Specialty Insurance & Risk Services Inc (TNT Gaming Center LLC v. American Specialty Insurance & Risk Services Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TNT Gaming Center LLC v. American Specialty Insurance & Risk Services Inc, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

TNT GAMING CENTER LLC and TNT § FAMILY ENTERTAINMENT, INC., § § Plaintiffs, § § Civil Action No. 3:24-CV-1995-K v. § § AMERICAN SPECIALTY INSURANCE § & RISK SERVICES, INC. ARCH § SPECIALTY INSURANCE COMPANY, § ST. PAUL FIRE AND MARINE § INSURANCE COMPANY, NANCY § WEIS, MICHAEL TRUMBULL, § CHRISTIAN AUXIER, NEAL § ANDERSON, and CRAWFORD & § COMPANY, § § Defendants. § MEMORANDUM OPINION AND ORDER Before the Court is the Motion for Remand (the “Motion”)(Doc. No. 10) filed by Plaintiffs TnT Gaming Center LLC and TnT Family Entertainment, Inc. Defendant Arch Specialty Insurance Company file a Response in Opposition (the “Response”) (Doc. No. 23). Plaintiffs filed a Reply (the “Reply”) (Doc. No. 29) in further support. The Court has carefully considered the Motion, the Response, the Reply, the relevant portions of the record, and the applicable law. Having considered the allegations in Plaintiffs’ state court petition, the Court concludes there is no reasonable basis to predict that Plaintiffs might recover against the non-diverse Defendants Michael Trumbull, Christian Auxier, and Neal Anderson. Accordingly, the Court finds Defendants Michael Trumbull, Christian Auxier, and Neal Anderson were improperly joined which compels their DISMISSAL without prejudice. Because the remaining

parties are completely diverse in their citizenship and the jurisdictional amount in controversy is met, the Court has subject matter jurisdiction over this matter and hereby DENIES Plaintiffs’ Motion to remand. I. Factual and Procedural Background

All case documents cited herein are to the CM/ECF assigned page number. Plaintiffs TnT Gaming Center LLC (“TnT Gaming”) and TnT Family Entertainment, Inc. (“TnT Entertainment”) (together, the “Plaintiffs” or “TnT”) own and operate an entertainment center that caters to families and offers an event space, entertainment/gaming center, and restaurant (the “Property”). Doc. No. 1-12 at 4.

According to Plaintiffs, they insured the business operations, contents, and building through Defendant St. Paul Fire and Marine Insurance Company (“St. Paul”) for TnT Gaming (the “St. Paul Policy”) and through Arch Specialty Insurance Company (“Arch”) for TnT Entertainment (the “Arch Policy”) (together with the St. Paul Policy,

the “Policies”). Id. at 5. Plaintiffs allege that, during the coverage periods of the St. Paul policy and the Arch policy, a fire started in a stove at the Property and the building and its contents were damaged by smoke and water as a result (the “Incident”). Id. Plaintiffs do not allege the dates of the Policy periods nor do they allege the date of the Incident. Plaintiffs allege that they reported the loss and filed claims with St. Paul and Arch, respectively. Plaintiffs claim they have fulfilled their obligations under both

Policies. Id. However, according to Plaintiffs, St. Paul and Arch “refuse to fully pay for the loss and claim” more than one year after the Incident which causes continuing damage to Plaintiffs. Id. St. Paul assigned Defendant Michael Trumbull as its adjuster for Plaintiffs’ claim. Id. Plaintiffs allege that Trumbull investigated their “loss, claim, and damages”

and “represent[ed] to Plaintiffs that if it were up to him, he would pay the claim.” Id. at 5, 6. Plaintiffs allege that “Trumbull and St. Paul have unreasonably delayed” deciding Plaintiffs’ claim, repeatedly stating that the fire department’s cause and origin report, which was not finalized, was needed to make a decision. Id. at 6. Because of

this, Plaintiffs further allege that “Trumbull and St. Paul” have “illegally ceded” and “surrendered to the fire department” their obligations and duties under the St. Paul Policy “to fully and fairly” and “independently” inspect, adjust, and determine Plaintiffs’ claim. Id.

Plaintiffs allege that their claim against the Arch Policy was “adjusted” by Defendants Nancy Weis and American Specialty Insurance & Risk Services, Inc. (“American Specialty”), along with Christian Auxier, Neal Anderson, and Crawford & Company (“Crawford”). Id. Plaintiffs allege that Defendants “Weis/American Specialty/Arch/Auxier/Anderson/Crawford” have “refused to pay the amount stated in

their consultants’ reports.” Id. Plaintiffs also allege that “Defendants Weis, American Specialty, Arch, Auxier, Anderson and/or Crawford” retained a professional engineer to inspect Plaintiffs’ electrical games and, although the engineer determined that the

games including their circuit boards must be replaced, “Defendants Weis, American Specialty, Arch, Auxier, Anderson and Crawford” have not paid for those replacements. Id. Plaintiffs go on to allege that “these Defendants” “have ceded” their obligations “to investigate, adjust, and make decisions” on Plaintiffs’ claim and have “ignored” information that is “contrary to their pre-determined and outcome-oriented narrative”

thereby “violating their duties to objectively adjust and make timely determinations” of Plaintiffs’ claims causing them harm. Id. 6-7. Addressing “all Defendants”, Plaintiffs allege they “provided ample documentation” numerous times, “allowed unfettered access” to the Property, “and

answered all questions asked.” Id. at 7. Despite all this, Plaintiffs alleges that “Defendants either refused to acknowledge receipt of same, continually claimed they did not receive those items they in fact did receive and/or continually requested the same information multiple times.” Id. The delay of the “Defendants” determining

Plaintiffs’ claims is, according to Plaintiffs, a denial of their claims. Id. As the result of “Defendants’” delay and failure to decide, Plaintiffs have been unable to reopen the Property and are at risk of losing the Property. Id. at 4, 7. Plaintiffs filed suit against these named Defendants in state court. In their First Amended Petition (the “Petition”), Plaintiffs assert the following claims: (1) vicarious

liability and agency against all Defendants; (2) breach of contract against Arch and St. Paul; (3) violations of the Texas Insurance Code against all Defendants; and (4) violations of the Texas Deceptive Trade Practices Act (the “DTPA”) against all

Defendants. Doc. No. 1-12 at 8-10. Defendant Arch removed the case to federal court under 28 U.S.C. § 1332(a). Doc. No. 1 at 3; see also id. at 6 (other Defendants consent to removal), 15-16 (jurisdictional amount in controversy met). In its Amended Notice of Removal, Defendant Arch properly alleged the citizenship of Plaintiffs TnT Gaming (Texas) and TnT Entertainment (Texas) which is completely diverse from that of

Defendants Arch (Missouri and New Jersey), American Specialty (Indiana), Weis (Indiana), Crawford (Georgia), and St. Paul (Connecticut) (collectively, the “Diverse Defendants”). Doc. No. 14 at 4-6. Defendant Arch asserts that, although Defendants Trumbull, Auxier, and Anderson (together, the “Non-Diverse Defendants”) are all

citizens of Texas, they were improperly joined to defeat diversity jurisdiction. Id. at 6- 16; see Doc. No. 1 at 5-15. Because the Non-Diverse Defendants were improperly joined, Defendant Arch argues the Court can disregard their citizenship for purposes of diversity jurisdiction.

Plaintiffs thereafter filed this Motion for Remand arguing, generally, that the Court lacks subject matter jurisdiction. The Motion to Remand is now fully briefed and before the Court for determination. II. Applicable Law A. Motion to Remand and Improper Joinder

Section 1441(a), the federal removal statute, allows the removal of any case brought in state court in which a federal court has original jurisdiction. 28 U.S.C.

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TNT Gaming Center LLC v. American Specialty Insurance & Risk Services Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tnt-gaming-center-llc-v-american-specialty-insurance-risk-services-inc-txnd-2024.