Travelers Property Casualty Company of America v. Jayco, Inc.

CourtDistrict Court, N.D. Indiana
DecidedMarch 26, 2025
Docket3:23-cv-00086
StatusUnknown

This text of Travelers Property Casualty Company of America v. Jayco, Inc. (Travelers Property Casualty Company of America v. Jayco, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Travelers Property Casualty Company of America v. Jayco, Inc., (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA,

Plaintiff,

v. Case No. 3:23-CV-86-CCB-SJF

JAYCO, INC., et al.,

Defendants.

OPINION AND ORDER This insurance subrogation matter is before the Court on a motion by Third- Party Defendant Patrick Industries, Inc. seeking summary judgment on Defendant Jayco, Inc.’s Third-Party claim for indemnification against it. (ECF 60). Based on the applicable law, facts, and arguments, Patrick Industries’ motion for summary judgment will be granted. I. FACTUAL BACKGROUND Preliminary Compliance Matter Patrick Industries’ summary judgment filings did not comply with the requirements set forth in N.D. Ind. L.R. 56-1 regarding statements of material facts. Local Rule 56-1(a)(3) requires the party moving for summary judgment to separately file a Statement of Material Facts. Rather than file its Statement of Material Facts separately, Patrick Industries incorporated its Statement into its brief in support of the motion. (See ECF 61 at 3–4). Similarly, Patrick Industries incorporated its response to Jayco’s Statement of Additional Facts into its reply brief in violation of Local Rule 56- 1(c)(2), which requires the separate filing of a “Reply to Statement of Additional Facts.”

(See ECF 76 at 3–4). Patrick Industries’ Reply to Statement of Additional Facts also violated Local Rule 56-1(c)(2) because it did not include “a verbatim restatement of the Statement of Additional Material Facts; [and] a correspondingly numbered response immediately following each paragraph of the Statement of Additional Material Facts . . . .” These violations do not affect the outcome of this motion, but did increase the time and resources necessary for the Court to assess the relevant disputed and

undisputed facts. The Court relies therefore on the factual statements filed in Jayco’s Response to Patrick Industries’ Statement of Material Facts and its own Statement of Additional Facts unless otherwise noted. (ECF 72). The facts that follow are largely not in dispute. Any disputed facts are either not material or will be addressed in the analysis below.

The Fire This lawsuit stems from a fire that occurred on March 19, 2021, at Patrick Industries’ facility in Elkhart, Indiana. Patrick Industries’ business involves painting of recreational vehicles (“RVs”) for which it maintains and operates paint booths at its Elkhart facility. In March 2021, Patrick Industries was providing painting goods and

services to Jayco, a subsidiary of Thor Industries, Inc., under an Agreement between Patrick Industries and Thor (“the Patrick/Thor Contract”) that incorporated the Thor Purchasing Policies and Procedures. Several of Jayco’s RV Units were in Patrick Industries’ possession when the fire broke out on March 19th. Patrick Industries employees had been applying clear coat to one of Jayco’s RV Units in a paint booth shortly before the fire began and had left the RV Unit “baking”

unattended while they performed other activities. The fire suppressant sprinkler system at or near the paint booth did not activate when the fire began and was still not fully active when the fire department arrived on scene. A fire department investigator later determined that the fire started in the paint booth containing a Jayco RV Unit, in or near the rear engine compartment. But the investigator could not determine the first fuel ignited; the ignition source; the ignition sequence that brought the first fuel ignited and

the ignition source together; or the cause of the fire. After the fire, Jayco worked with Patrick Industries to refurbish and resell the salvageable RV Units, and Patrick Industries agreed that Jayco would retain the proceeds from the sale of the RV Units. On November 18, 2021, Patrick Industries agreed to reimburse Jayco for certain costs to repair the RV Units and the loss in value

of the RV Units when resold. On January 6, 2022, Patrick Industries paid Jayco $582,699 to cover Jayco’s loss on the four burnt RVs. At the time of the fire, Patrick Industries was insured by Plaintiff Travelers Property Casualty Company of America1. After the fire, Patrick Industries submitted a

1 Patrick Industries does not cite evidence supporting this purported fact, or any fact related to its relationship with Travelers, in its briefing or its Statement of Material Facts as required by Fed. R. Civ. P. 56(c)(1) and N.D. Ind. L.R. 56-1(a)(3)(B). Patrick Industries cites only rhetorical paragraphs in Travelers’ First Amended Complaint in support. (ECF 61 at 4). Jayco objects to the lack of proper citation but not to the asserted facts themselves. (ECF 72 at 4). Therefore, Patrick Industries’ lack of compliance with the applicable rules does not require any finding or sanction under Fed. R. Civ. P. 56(e)(2) and N.D. Ind. L.R. 56-1(e) because the facts at issue are undisputed. claim to Travelers for fire damage to its Elkhart facility. Under the insurance policy, Travelers compensated Patrick Industries for the fire damage to the facility. Procedural History

On January 31, 2023, Travelers, as subrogee of Patrick Industries, initiated this lawsuit to recover monies paid out under the insurance policy related to the March 2021 fire. (ECF 1). The operative First Amended Complaint alleges negligence against Jayco, Defendant MORryde International, Inc., and Defendant The Shyft Group USA, Inc. d/b/a Spartan RV Chassis. (ECF 7). In response to the First Amended Complaint, Jayco

filed its answer and affirmative defenses, including, but not limited to, comparative fault and intervening and superseding causes. (ECF 17 at 16). As to both affirmative defenses, Jayco alleges that Patrick Industries caused the fire damage in whole or in part. (Id.). Jayco also asserted indemnification claims against Travelers in a counterclaim and against Patrick Industries in a third-party complaint. (Id. at 21–22). Through both

indemnification claims, Jayco invoked the Patrick/Thor Contract. The Contract contains an “Indemnity Clause” that provides: Indemnity. Supplier2 will defend, indemnify, and hold Thor3 harmless from and against any and all claims, demands, and/or causes of action seeking to recover any economic, property, personal injury and/or other damages incurred by or recovered from Thor predicated upon, arising out of or related to: (1) an alleged defect in the design, manufacture or assembly of any Product(s)4 provided by Supplier to Thor; (2); an alleged

2 The term “Supplier” is not defined in the Purchasing Policies and Procedures document designated by both parties. (ECF 61-2, 72-1). The Court infers from the parties’ briefing that the term “Supplier” means Patrick Industries. 3 As relevant here, the term “Thor” is defined as “Thor Industries, Inc. and each of Thor’s current and future operating subsidiaries based in the United States, including those entities referenced at the bottom of this document . . . .” (ECF 61-2 at 2). Jayco is referenced at the bottom of the Purchasing Policies and Procedures document. (Id. at 9). Therefore, references in the Indemnity Clause to “Thor” include Jayco. 4 “Product(s)” are defined to include Patrick Industries’ “goods and services” collectively. (Id. at 2).

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Travelers Property Casualty Company of America v. Jayco, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/travelers-property-casualty-company-of-america-v-jayco-inc-innd-2025.