USAA Casualty Insurance Company v. Nuvo Residential LLC

CourtDistrict Court, D. Arizona
DecidedAugust 20, 2025
Docket2:22-cv-01512
StatusUnknown

This text of USAA Casualty Insurance Company v. Nuvo Residential LLC (USAA Casualty Insurance Company v. Nuvo Residential LLC) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USAA Casualty Insurance Company v. Nuvo Residential LLC, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8

USAA Casualty Insurance Company, ) No. CV-22-01512-PHX-SPL ) 9 ) 10 Plaintiff, ) ORDER vs. ) ) 11 ) Nuvo Residential LLC, et al., ) 12 ) 13 Defendants. ) ) 14 )

15 Before the Court is Defendant Hydro Systems International, Inc.’s (“Defendant 16 Hydro”) Motion for Attorneys’ Fees and Expert Costs against Co-Defendant and Cross 17 Claimant Nuvo Residential LLC (“Defendant Nuvo”) (Doc. 96), Defendant Nuvo’s 18 Response (Doc. 100), and Defendant Hydro’s Reply (Doc. 102). For the following reasons, 19 the Court will grant Defendant Hydro’s Motion for fees in part as modified and deny as to 20 Defendant Hydro’s request for expert costs. 21 I. BACKGROUND 22 This case arises out of an incident in which a water softener system owned by 23 Patrick Maley failed, flooded his residence, and caused water damage. (Doc. 79 at 2). 24 Maley was insured by Plaintiff USAA Casualty Insurance Company, which filed this 25 subrogation action against Defendants. (Doc. 11). On October 4, 2022, Plaintiff filed its 26 Amended Complaint against Defendants Nuvo and Hydro, bringing strict products liability 27 and negligence claims. (Id. at 1). Plaintiff alleges the water damage was due to a failure of 28 Defendant Nuvo’s H2O water softener and its component parts. (Id. at 4–5). Specifically, 1 Plaintiff alleges the water softener system experienced a “crack in the head,” which is one 2 of the system’s three core component parts. (Docs. 79 at 3; 11 at 5–6). Defendant Nuvo 3 allegedly purchased the head and another component part, the canister, (collectively 4 referred to as “housings”) from Defendant Hydro, a distributor of water treatment products. 5 (Doc. 79 at 3). Defendant Nuvo custom designs the third core component part, the 6 cartridge, and outsources its manufacturing to various companies. (Id. at 3–4). 7 On November 8, 2022, Defendant Nuvo filed a cross-claim against Defendant 8 Hydro, seeking indemnity and reimbursement of attorneys’ fees and costs from Defendant 9 Hydro in this matter pursuant to A.R.S. § 12-684 and common law. (Doc. 20 at 6). 10 Defendant Nuvo alleged that Defendant Hydro designed and manufactured the head of the 11 housing, which Plaintiff alleged was defective and caused the water loss, and that Nuvo 12 had no knowledge or hand in altering, modifying, or installing the water softener system at 13 issue. (Id. at 5–6). On July 26, 2024, Defendant Hydro filed a Motion for Summary 14 Judgment to dismiss Nuvo’s indemnity cross-claim (Doc. 79), which the Court granted on 15 December 13, 2024, relieving Defendant Hydro of liability (Doc. 91). Defendant Hydro 16 subsequently filed the present Motion for Attorneys’ Fees and Expert Costs seeking 17 $385,279 in attorneys’ fees and $234,721 in expert costs pursuant to Federal Rule of Civil 18 Procedure (“Rule”) 54(d)(2), or alternatively, A.R.S. § 12-341.01. (Doc. 96). Defendant 19 Nuvo concedes that a fee award is permitted but argues that the requested award is 20 unreasonably excessive and thus must be sharply reduced. (Doc. 100). 21 II. DISCUSSION 22 Defendant Hydro first argues that attorneys’ fees are warranted under Italian law, 23 pursuant to Defendant Hydro and Nuvo’s business contract that provided for the 24 applicability of Italian law in the event of a contract dispute between the parties. (Doc. 96 25 at 2). Alternatively, Defendant Hydro argues that it should receive attorneys’ fees under 26 A.R.S. § 12-341.01, if the Court determines that Italian law does not apply. (Id.). Defendant 27 Nuvo argues that Arizona, not Italian, law is appropriate in this case, but that under either 28 scheme, a sharp reduction in the requested fees is warranted. (Doc. 100 at 1, 3). As a 1 threshold matter, the Court must determine whether Italian law, pursuant to the parties’ 2 contractual agreement, or Arizona law governs recovery of attorneys’ fees, before it can 3 determine whether the requested fees are reasonable under the appropriate scheme. 4 a. Choice of Law 5 “In a diversity case, the district court must apply the choice-of-law rules of the state 6 in which it sits.” Abogados v. AT&T, Inc., 223 F.3d 932, 934 (9th Cir. 2000) (citing Klaxon 7 Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487, 496 (1941)). Under Arizona’s choice-of-law 8 rules, procedural matters are governed by the law of the forum, and substantive matters are 9 governed by “the law of the jurisdiction to which the court is referred by the choice-of-law 10 rules of the forum.” Cardon v. Cotton Lane Holdings, Inc., 841 P.2d 198, 201 (Ariz. 1992) 11 (citation omitted). In Arizona, attorneys’ fees are a substantive issue. See Delevin v. 12 Holteen, CV-12-00118-TUC-FRZ, 2016 WL 10721809, at *2 (D. Ariz. Apr. 26, 2016), 13 aff’d, 687 Fed. Appx. 532 (9th Cir. 2017) (“After review of relevant case law, the Court 14 determines that Arizona law labels attorneys’ fees as substantive.”). 15 “Arizona courts apply the Restatement (Second) of Conflict of Laws 16 (“Restatement”) to determine the law governing multi-state (and presumably multi- 17 national) tort claims.” Magellan Real Estate Inv. Tr. v. Losch, 109 F. Supp. 2d 1144, 1155 18 (D. Ariz. 2000) (citing Bates v. Superior Court of Arizona, 749 P.2d 1367, 1369 (Ariz. 19 1988)); see also Kirkpatrick v. Hubman, CV-21-01048-PHX-DJH, 2022 WL 1443762, at 20 *4 (D. Ariz. May 6, 2022). Under the Restatement, a contract’s choice-of-law provision is 21 valid and enforceable if the contract issue brought by the parties is “one which the parties 22 could have resolved by an explicit provision in their agreement directed to that issue.” 23 Restatement (Second) of Conflict of Laws § 187 (1971). If there is no explicit provision 24 directed to a particular issue, the chosen forum will still be applied unless either: 25 (a) the chosen state has no substantial relationship to the parties or the transaction and there is no other reasonable basis for the 26 parties’ choice, or 27 (b) application of the law of the chosen state would be contrary to a fundamental policy of a state which has a materially 28 greater interest than the chosen state in the determination of the particular issue and which, under the rule of § 188, would be 1 the state of the applicable law in the absence of an effective choice of law by the parties. 2 3 Restatement (Second) of Conflict of Laws § 187(2) (1971). Here, the contract between 4 Defendants Hydro and Nuvo provides the following: 5 Applicable Law and Settlement of Disputes: 6 This Contract shall be governed and regulated by CISG (United Nations Convention on Contracts for the International 7 Sale of Goods, Vienna 1980). Any questions not covered by CISG will be governed by the law of Italy. Any dispute may 8 arise between Hydro Systems International NY and the Customer in connection with this Contract, its interpretation, 9 performance, breach of termination shall be finally referred to the Court of Reggio Emilia – Italy.” [Document 96-2, p. 6, 10 citing Document 80-6, p. 145.] 11 (Docs. 96 at 6; 100 at 4). There is no explicit provision that speaks to the issue of attorneys’ 12 fees.

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Bluebook (online)
USAA Casualty Insurance Company v. Nuvo Residential LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/usaa-casualty-insurance-company-v-nuvo-residential-llc-azd-2025.