TPA Risk Management LLC v. Buckeye Dealership Consulting, LLC

CourtDistrict Court, N.D. Ohio
DecidedMay 13, 2025
Docket4:24-cv-00161
StatusUnknown

This text of TPA Risk Management LLC v. Buckeye Dealership Consulting, LLC (TPA Risk Management LLC v. Buckeye Dealership Consulting, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TPA Risk Management LLC v. Buckeye Dealership Consulting, LLC, (N.D. Ohio 2025).

Opinion

PEARSON, J. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

TPA RISK MANAGEMENT, LLC, ) ) CASE NO. 4:24CV0161 Plaintiff, ) ) v. ) JUDGE BENITA Y. PEARSON ) BUCKEYE DEALERSHIP ) CONSULTING, LLC, etc., ) MEMORANDUM OF OPINION ) AND ORDER Defendant. ) [Resolving ECF Nos. 36 and 44]

Pending is Defendant Buckeye Dealership Consulting, LLC d/b/a Specialty Administration Services’ Motion for Summary Judgment (ECF No. 36). Defendant moves the Court for judgment as a matter of law against Plaintiff on all of its claims because the parties did not form a binding term contract. Also pending is Plaintiff TPA Risk Management LLC’s Motion for Partial Summary Judgment (ECF No. 44). Plaintiff moves the Court for summary judgment, in whole or in part, on (1) Counts I, I and IV of the Complaint (ECF No. 1); (2) Defendant’s accord and satisfaction defense (Answer and Counterclaim (ECF No. 10 at PagelD #: 101, 4); and (3) the Counterclaims (ECF No. 10). The Court has been advised, having reviewed the record, the parties’ briefs, and the applicable law. For the reasons that follow, the Court finds the 2023 Agreement (ECF No. 36-6) is an enforceable contract. Therefore, the Court grants Plaintiff's motion in part and denies Defendant’s motion.

(4:24CV0161) I. Stipulated Facts The stipulated facts1 are as follows: 1. In the fall of 2020, Defendant first retained Plaintiff to assist in reviewing Defendant’s

vehicle warranty claims. 2. On or about September 4, 2020, the parties executed an agreement relating to Plaintiff’s consulting services (“2020 Agreement”). 3. A true and accurate copy of the 2020 Agreement was marked as Deposition Exhibit 4 (marked first during the deposition of Robert Fox, Sr.). See ECF No. 38-4. 4. The initial term of the 2020 Agreement was September 4, 2020 to December 31, 2020, but the parties extended the term into early 2021. 5. The 2020 Agreement provided for a fixed monthly payment of $8,500 plus reasonable

expenses. 6. In or around September 2022, Defendant retained Plaintiff to perform an audit of Defendant’s claims process (“Audit Agreement”). 7. The parties agreed that Plaintiff would be paid a flat fee of $9,750 for the audit of Defendant’s claims process. 8. A true and accurate copy of the Audit Agreement was marked as Deposition Exhibit 6 (marked first during the deposition of Robert Fox, Sr.). See ECF No. 38-6.

9. According to Rob Fox, Defendant’s Chief Executive Officer, the audit showed that Defendant’s claims process was “sloppy.” 1 See Stipulation of Uncontested Facts (ECF No. 37). 2 (4:24CV0161) 10. In mid-October 2022, the parties executed another agreement (“2022 Agreement”). 11. A true and accurate copy of the 2022 Agreement was marked as Deposition Exhibit 14 (marked first during the deposition of Robert Fox, Sr.). See ECF No. 38-14.

12. Under the 2022 Agreement, Plaintiff agreed to perform certain services, and Defendant agreed to share 50% of the claims severity savings with Plaintiff. 13. The term “claims severity” refers to the amount paid per claim. 14. The 2022 Agreement stated that the term of the agreement was four years; however, the agreement mistakenly stated that the term would run from “October 15th, 2022, to October 31st, 2022” S a period of just 16 days. 15. In early January 2023, the parties executed an agreement that corrected the date range for the term of the agreement (“2023 Agreement”). See ECF No. 36-6.

16. The 2023 Agreement provided that Defendant would share 50% of the claims severity savings with Plaintiff. 17. The 2023 Agreement added the following: “The actual average cost will be agreed upon by both parties by December 1, 2022 and will be included as an addendum to this agreement.” ECF No. 36-6 at PageID #: 294. 18. In the fall of 2023, Plaintiff sent Defendant a calculation for the amount that Plaintiff claimed was due under the 2023 Agreement, and Defendant disputed that Plaintiff was entitled to

this amount.

3 (4:24CV0161) 19. On or about November 7, 2023, Vinny Miller and Justin Thompson (representatives of Plaintiff) and A.J. Johnson and Jacob Jeswald (representatives of Defendant) participated in a Microsoft Teams call.

20. During the November 7, 2023 Teams call, the parties were unable to agree on the amount owed to Plaintiff. 21. On November 8, 2023, Vinny Miller emailed Rob Fox and stated in part: I cannot spend any more time trying to fight for what is owed to us for the value we brought your company. I am trying to take care of other customers like you and helping my 25-year-old son who is fighting for his life with stage 4 cancer. I know that it may not be important to you, but it is VERY important to me. Just pay me what you think we are owed so we can catch up on the 14 months’ worth of work we have provided to [Specialty Administration Services]. Let me know when to expect our past due funds.2 ECF No. 36-7 at PageID #: 298-99. 22. On November 20, 2023, Defendant sent a letter to Plaintiff via email. See ECF No. 36-8. 23. The letter informed Plaintiff that Defendant was terminating the relationship and that Defendant intended to transmit $435,231.26 as payment for what Defendant owed Plaintiff. 24. Defendant authorized the payment of $435,231.26 to Plaintiff, and this payment was received by Plaintiff.

2 The parties stipulate to the accuracy of the above-quoted language, but reserve the right to object at trial to the admissibility of certain aspects of this language. 4 (4:24CV0161) II. Background Plaintiff is a third-party claims administrator of vehicle service contracts. Its webpage advertises Plaintiff as a “consulting services company, providing advisory services and solutions

for organizations currently doing business in the Vehicle Service Contract (VSC) Industry.” It claims that Plaintiff can “minimize risk exposure, improve claims, handling procedures and . . . provide technical and procedural training.” ECF No. 36-1. Buckeye Dealership Consulting, LLC (“Buckeye”) operates in the “buy here/pay here” (“BHPH”) sector of the automobile dealership community, providing services such as vehicle service contracts, warranties, and other ancillary products that a consumer may want to protect the car. See Deposition of Robert R. Fox, Sr. (ECF No. 38-1) at 14:20-15:2. Buckeye has established itself in the BHPH marketplace and has experienced significant growth over the last six years. See ECF No. 38-1 at 14:9-12.

Specialty Administration Services (“SAS”) is a division of Buckeye that primarily administers lender coverage on medium and heavy-duty trucks. See ECF No. 38-1 at 17:18-20; 18:23-19:1-3. In 2022, Defendant retained Plaintiff to assist in reducing its average claims severity, i.e., the average amount paid per claim.3

3 During Plaintiff’s audit of Defendant (which occurred just before the parties executed the 2022 Agreement (ECF No. 38-14)), Plaintiff identified numerous claims that were problematic. Rob Fox was furious about the issues identified during the audit: A. . . . We paid a heavy-duty claim off a picture of a medium-duty transmission. Q. Uh-huh. A. That just set me on fire. ECF No. 38-1 at 58:4-8. 5 (4:24CV0161) In the year leading up to the 2022 Agreement (ECF No. 38-14), Defendant’s average claims severity was $2,629.13. Declaration of Vinh Miller (ECF No. 48-1) at PageID #: 1090, 4] 24. After the parties executed the 2022 Agreement (ECF No. 38-14), Plaintiff, among other things, trained and monitored Defendant’s adjusters and provided feedback; assisted Defendant in searching for new adjusters; provided a claims checklist to assist in processing claims; reviewed larger claims and made recommendations; and, identified potential vendors that could reduce Defendant’s costs. ECF No. 48-1 at PageID #: 1090, 9.25.

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