Vo v. Federal Ins. Co.

CourtSupreme Court of Virginia
DecidedApril 16, 2015
Docket140297
StatusPublished

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

Bluebook
Vo v. Federal Ins. Co., (Va. 2015).

Opinion

Present: All the Justices

CHRISTOPHER BARTOLOMUCCI OPINION BY v. Record No. 140275 JUSTICE LEROY F. MILLETTE, JR. April 16, 2015 FEDERAL INSURANCE COMPANY, ET AL.

VU VO

v. Record No. 140297

FEDERAL INSURANCE COMPANY, ET AL.

FROM THE CIRCUIT COURT OF LOUDOUN COUNTY Thomas D. Horne, Judge

In these appeals we consider the scope and application of

an insurance policy that provides coverage for a law firm

partner's vehicle only when that vehicle is "used in" a law

firm's business or personal affairs.

I. Facts And Proceedings

Vu Vo and Christopher Bartolomucci were involved in a

vehicle collision. Based on his injuries, Vo filed a lawsuit

against Bartolomucci seeking $1,000,000 in damages. The

vehicle which Bartolomucci was driving was insured under an

Allstate Insurance Company insurance policy with a $100,000

liability limit (the "Allstate Policy"). Vo is unwilling to

settle his suit within the Allstate Policy's limit.

Because his potential liability exceeds the Allstate

Policy's limit, Bartolomucci filed a declaratory judgment

action in the Circuit Court of Loudoun County. Bartolomucci sought to establish that his vehicle fell within the scope of

Federal Insurance Company's insurance policy issued to

Bartolomucci's law firm, Hogan Lovells US, LLC (the "Federal

Policy"). 1 During the course of these proceedings, the circuit

court ruled on the demurrer to the amended complaint filed by

Federal Insurance and Hogan Lovells. The circuit court

sustained that demurrer in part, overruled it in part, and

allowed Bartolomucci's suit to continue on the theory that he

was covered by the Federal Policy.

The case went to trial. The matter was submitted to the

jury on a special interrogatory asking the question whether

Bartolomucci was using his vehicle in Hogan Lovells's business

or personal affairs at the time of the collision. The jury

responded "yes." However, the circuit court then granted

Federal Insurance's and Hogan Lovells's motion to strike, and

set aside the jury's finding as not being supported by the

evidence. The court entered final judgment in favor of Federal

Insurance and held that the Federal Policy did not cover

Bartolomucci's use of the vehicle at the time of the collision.

Bartolomucci and Vo timely filed separate petitions for

appeal with this Court, and we granted all six assignments of

error. These assignments require us to address four issues:

1 At the time of the collision, Hogan Lovells US, LLC was Hogan Hartson, LLC. All instances of Hogan Hartson are referred to as Hogan Lovells.

2 1. Whether the Federal Policy automatically provided excess liability coverage unrestricted by any other requirements of the policy?

2. Whether the Federal Policy provided coverage because Bartolomucci is a "Named Insured"?

3. Whether the Federal Policy provided coverage because it is ambiguous?

4. Whether the Federal Policy provided coverage because Bartolomucci's use of the vehicle fell within the scope of the policy?

II. Discussion

A. The Role Of The Jury In A Declaratory Judgment Action

The parties dispute the preliminary issue of whether the

jury's answer of "yes" to the special interrogatory was binding

or advisory. Throughout the proceedings, the circuit court

treated the jury's answer as arising under Code § 8.01-188, and

as binding subject to being set aside only in the limited

circumstances set forth in Code § 8.01-680. Federal Insurance

argues that this was error because no constitutional,

statutory, or consent basis allowed the court to employ a

binding jury, and therefore the jury's answer was only advisory

under Code § 8.01-336(E). See Angstadt v. Atlantic Mut. Ins.

Co., 254 Va. 286, 291-92, 492 S.E.2d 118, 120-21 (1997); Wright

v. Castles, 232 Va. 218, 222, 349 S.E.2d 125, 128 (1986). This

argument impacts our review of the circuit court's treatment of

the jury answer. If the jury's answer was binding rather than

advisory, the court's setting aside that answer is analyzed

3 under a more stringent standard. Compare DeJarnette v. Thomas

M. Brooks Lumber Co., 199 Va. 18, 21, 97 S.E.2d 750, 752 (1957)

(standard of review applicable to the rejection of an advisory

determination), with Wooldridge v. Echelon Service Co., 243 Va.

458, 461, 416 S.E.2d 441, 443 (1992) (standard of review

applicable to the setting aside of a binding verdict).

We decline to resolve this issue because we need not do so

to decide this appeal. See Woodard v. Commonwealth, 287 Va.

276, 280-81, 754 S.E.2d 309, 312 (2014). For the reasons set

forth in this opinion, the circuit court's action was without

error even under the more stringent standard of review. For

purposes of this appeal, we assume without deciding that the

jury's answer to the special interrogatory was binding.

B. The Federal Policy And Final Judgment
1. Standard Of Review

Because we treat the jury's answer to the special

interrogatory as binding rather than advisory, "the jury

verdict must be reinstated and judgment entered on the verdict

if there is any credible evidence in the record to support the

jury verdict." Wooldridge, 243 Va. at 461, 416 S.E.2d at 443.

To the extent we interpret and apply the terms of an

insurance contract, we address those issues of law de novo.

Doctors Co. v. Women's Healthcare Assocs., 285 Va. 566, 571,

740 S.E.2d 523, 525 (2013).

4 2. The Federal Policy

The Federal Policy is comprised of two documents: the

Business Auto Declarations and the Business Auto Coverage Form.

The Business Auto Declarations instrument sets forth the basics

of the Federal Policy, such as the Named Insured, endorsements,

and a schedule of coverages. The Business Auto Coverage Form

instrument sets forth the terms of the policy and resembles a

traditional contract. We review these documents "as if their

several provisions were in one and the same instrument."

Bailey v. Town of Saltville, 279 Va. 627, 633, 691 S.E.2d 491,

493 (2010) (internal quotation marks and citation omitted).

a. The Excess Coverage Provision Does Not Provide An Independent Basis To Establish Excess Coverage

In provision IV.B.5.a., the Business Auto Coverage Form

provides: "For any covered 'auto' you don't own, the insurance

provided by this Coverage Form is excess over any other

collectible insurance." Bartolomucci assigns error to the

circuit court's failure to hold that he fell within this

language, as in his view the Federal Policy operates as excess

insurance for vehicles not owned by Hogan Lovells.

Bartolomucci's argument is that the Federal Policy applied to

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