Truck Ins. Exchange v. Fed. Ins. Co.

CourtCalifornia Court of Appeal
DecidedMay 12, 2025
DocketB332397
StatusPublished

This text of Truck Ins. Exchange v. Fed. Ins. Co. (Truck Ins. Exchange v. Fed. Ins. Co.) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Truck Ins. Exchange v. Fed. Ins. Co., (Cal. Ct. App. 2025).

Opinion

Filed 5/12/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION EIGHT

TRUCK INSURANCE B332397 EXCHANGE, (Los Angeles County Plaintiff and Appellant, Super. Ct. No. 19STCV26702) v.

FEDERAL INSURANCE COMPANY,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Richard Fruin, Jr., Judge. Affirmed in part, reversed in part, and remanded with directions.

Pia Hoyt, Scott R. Hoyt, John Phillip Mertens; Greines, Martin, Stein & Richland, Edward L. Xanders and Stefan C. Love for Plaintiff and Appellant.

Keaster Law Group, Robert W. Keaster, Michael C. Denlinger; Hinshaw & Culbertson and Robert J. Romero for Defendant and Respondent.

_______________________ INTRODUCTION California law does not require one insurer to contribute to or reimburse another insurer who makes a voluntary payment. (See OneBeacon America Ins. Co. v. Fireman’s Fund Ins. Co. (2009) 175 Cal.App.4th 183, 199–200; see Truck Ins. Exchange v. Unigard Ins. Co. (2000) 79 Cal.App.4th 966, 974; see also Civ. Code, § 1432.) This is the third case involving two insurance carriers arguing whether one was required to reimburse the other for defense costs expended under an umbrella policy for the insured. Appellant Truck Insurance Exchange (Truck) argues that the settlement it reached with Federal Insurance Company (Federal) to end the first litigation in 2013 was procured by Federal’s fraudulent misrepresentation and concealment. Federal did not disclose it had no duty to pay the insured’s defense fees but had made a business decision to do so “at its option.” Truck argues it would have never agreed to pay $4.9 million in settlement had it known Federal contributed to the insured’s defense voluntarily “at its own expense.” On appeal, Truck contends the trial court addressed the claim for fraudulent misrepresentation but failed to address the fraudulent concealment claim. Truck argues we should reverse and remand for a new trial. We agree. Federal argues independent grounds warrant affirming the judgment against Truck. We disagree with Federal.

FACTUAL AND PROCEDURAL BACKGROUND I. Factual Background Since 1986, more than 30,000 plaintiffs have filed lawsuits against Moldex-Metric, Inc. (Moldex), alleging Moldex manufactured defective air respirators and masks that failed to

2 protect them from inhaling silica, asbestos, and mixed dust leading to bodily injury. Moldex gave notice of the lawsuits to its primary liability insurers, who defended and indemnified Moldex. In 2003, when the primary insurers’ policy limits were exhausted, Moldex gave notice of the lawsuits to its excess and umbrella liability insurers—Federal and First State Insurance Company (First State)—which began to indemnify and pay for Moldex’s defense in the lawsuits. On December 20, 2004, Moldex belatedly discovered it was additionally insured under a primary liability policy issued by Truck and sought coverage from Truck. Federal and First State sought contribution from Truck for the indemnity and defense fees they had already paid Moldex under their respective umbrella policies. Litigation ensued. II. Federal’s Umbrella Policy We recite two provisions from Federal’s umbrella policy, which come into play throughout the parties’ litigation: Section 3, entitled “Limits of Liability,” provides in part: “In the event that the aggregate limits of liability of the underlying policies, listed in the schedule of underlying insurance, are exhausted . . . this policy shall, subject to the Company’s limit of liability and to the other terms of this policy, with respect to occurrences which take place during the period of this policy, continue in force as underlying insurance for the remainder of the policy year of the underlying policy or until the Company’s aggregate limit of liability . . . is exhausted.” Section 4(a) entitled “DEFENSE PROVISIONS” provides: “The Company [Federal] shall not be called upon to assume charge of the investigation, settlement or defense of any claim made, or suit brought, or proceeding instituted against the

3 insured [Moldex], but shall have the right and be given the opportunity to be associated in the defense and trial of any such claims, suits or proceedings relative to any occurrence which, in the opinion of the Company, may create liability on part of the Company under the terms of this policy. If the Company avails itself of such right and opportunity the Company shall do so at its own expense.” (Italics added.) III. Case #1: Federal’s Reimbursement Action On September 20, 2007, Federal filed a complaint against Truck for contribution, reimbursement, and declaratory relief (L.A. Super. Court case No. BC377842). Federal alleged it undertook Moldex’s defense and indemnified Moldex without reservation pursuant to the terms of the Federal policy.1 However, in light of the existence of available and unexhausted primary insurance, Federal, as an umbrella insurer, had no duty to defend on Moldex’s behalf. “[A]s the Truck policy is a primary policy and the Federal policy is an umbrella policy, it is the Truck policy that should have responded to [Moldex’s] actions.” Federal alleged that because of the Truck primary policy, Truck was obligated to reimburse Federal for the amounts it had paid. Federal sought reimbursement from Truck for approximately $4.5 million in defense costs and $98,945 in indemnity costs, plus interest thereon. On December 19, 2007, Truck filed an answer denying the allegations of Federal’s complaint. It asserted 38 affirmative defenses, including the following as its 23rd defense: “To the

1 The term “without reservation” means that the insurer is providing a defense without retaining a right to challenge the insured’s right under the policy to receive such benefit.

4 extent that Moldex and/or Federal voluntarily paid, assumed an obligation to pay, or incurred an expense without notice and approval by Truck, Truck has no obligation to Moldex and/or Federal for any such payment, obligation or expense.” (Some capitalizations omitted.) On November 24, 2009, Federal filed a motion for summary judgment on its cause of action for declaratory relief as to reimbursement from Truck in the amount of $3,854,391 in defense costs and $98,213 in indemnity. Federal argued: “As the Court knows, Federal defended and indemnified [Moldex] pursuant to an excess policy of insurance . . . following the exhaustion of all then-known primary policies. . . . The law requires that Truck reimburse Federal for amounts paid by Federal in defense.” “The law is also clear that before coverage attaches pursuant to an excess policy, the policy limits of the underlying primary policy must be exhausted. As such, the law requires that the entire loss be shifted to the one who was primarily liable for the loss, Truck.” (Italics omitted.) On June 3, 2011, the trial court granted Federal’s motion for summary judgment. “Simply put, all available primary coverage has to exhaust before the excess carriers have any duty to share in the continuing expense of defending and settling claims.” Following years of litigation, on February 28, 2013, the trial court entered judgment against Truck, awarding approximately $6 million to Federal ($3,854,391 in defense costs plus $1,992,058 interest and $98,213 in indemnity costs plus $56,835 interest). The court found Federal contributed to “the defense costs Moldex incurred after December 20, 2004 under an umbrella policy” and that Truck had a duty to defend Moldex

5 pursuant to its primary liability policy upon Moldex’s December 20, 2004 tender of notice to Truck about the lawsuits. The trial court further found Truck had a duty to reimburse Federal and First State for their payments of Moldex’s defense and indemnity incurred between December 2004 and June 2011.

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