Wall v. Country Mut. Ins. Co.

319 F. Supp. 3d 1227
CourtDistrict Court, W.D. Washington
DecidedMay 17, 2018
DocketCASE NO. C17-446 MJP
StatusPublished
Cited by9 cases

This text of 319 F. Supp. 3d 1227 (Wall v. Country Mut. Ins. Co.) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wall v. Country Mut. Ins. Co., 319 F. Supp. 3d 1227 (W.D. Wash. 2018).

Opinion

Plaintiffs' other alleged proof of unreasonableness is the "misrepresentation" by Defendant's agent that the jewelers he spoke to informed him that the time it takes to clean a diamond ring was not sufficient time to switch out the stone and cover up the pry marks that would be left. Plaintiffs claim that what the agent had in fact been told was that the switching out and sanding off/polishing could all have been done within the 10-15 minutes which the standard cleaning takes. Their proof of this is a declaration from the owner of Anthony's Jewelry to that effect, and a declaration that that is what he told Thielbar. (Decl. of Ethier at ¶¶ 9-10.)

There are a number of problems with this that preclude summary judgment. First, Ethier says "I informed Mr. Thielbar that the total time a professional jeweler/goldsmith would require to remove and reset a stone such as the one at issue would be five to ten minutes." (Id. at ¶ 9; emphasis supplied.) And, then,

[m]y estimate of five to ten minutes to remove and reset a stone such as the stone at issue includes the time it would require to polish or sand off any pry marks that would occur from the removal and resetting process.

(Id. at ¶ 10.) But the declaration does not say "I told Thielbar that my 5-10 minute estimate included sanding off or polishing." In fact, what he says he told Thielbar is that "removing and resetting" took five to ten minutes. It is equally likely that this is simply an instance of poor communication on the jeweler's part, rather than misrepresentation on the investigator's part.

Plaintiffs' evidence of scienter is further undercut by Thielbar's notes in the Claim Activity Log. His record of the interview with Ethier reflects that he was told "a professional jeweler/goldsmith could remove and reset a 2ct diamond w/in 5-10 minutes," and that

when stones are set, they are not glued in and are simply held in place by the prongs clamping down around the stone. Anthony said that if/when a stone is removed/reset there would be pry marks on the prongs unless/until these marks could be sanded/polished off.

(Claim Activity Log at 13-14.) There is no indication in the notes that Thielbar was told that the 5-10 minute estimate included the time required to polish/sand off the pry marks. Furthermore, Thielbar's notes reflect the exact same "remove and reset" language that Ethier used in his own declaration, language which does not intuitively suggest that what was actually meant was "remove, reset, and sand/polish off pry marks. " It is not possible, looking at this evidence in the light most favorable to the non-movant, that the Court can rule that there are no disputes of material fact (concerning what Theilbar was told or knew)5 or that Plaintiffs are entitled to a *1233finding of "bad faith" conduct or "unreasonable denial" as a matter of law.

The Court will DENY Plaintiffs' motion for summary judgment.

Defendant's Motion for Summary Judgment

Turning to Defendant's motion: much of Defendant's legal position on summary judgment is grounded in the theory that, because it ultimately turned out that there had been no theft and therefore no covered loss, their denial of coverage was not unreasonable and there can be no actionable claim for a violation of IFCA or the CPA, nor a bad faith violation of their contract. Tellingly, they cite no legal support for this assertion.

The legal reality is exactly the opposite. There is an abundance of case law that an insurance company can be held liable for bad faith and unreasonable conduct in the investigation and denial of a claim even where it ultimately turns out that there was no coverage. "[W]hether a coverage decision is correct ... is not dispositive of [a] bad faith claim." Bryant v. Country Life Ins. Co., 414 F.Supp.2d 981, 1000 (W.D. Wash. 2006).

The issue is "whether Insurer's denial of coverage was unreasonable when it occurred, not whether later developments could have vindicated the Insurer's decision." Fireman's Fund Ins. Co.'s v. Alaskan Pride P'ship, 106 F.3d 1465, 1470 (9th Cir. 1997). Washington's Supreme Court has held that "an insured may maintain an action against its insurer for bad faith investigation of the insured's claim ... regardless of whether the insurer was ultimately correct in determining that coverage did not exist." Coventry v. American States Ins. Co., 136 Wash.2d 269, 279, 961 P.2d 933 (1998).

It is clear, throughout the course of this claim process and investigation, that all parties believed that the original stone had been stolen. The issue in everyone's mind was not whether Plaintiffs had suffered a loss, but when and where that loss had occurred and whether the loss was covered by the policy with Defendant. Defendant is absolutely bound by its obligation to conduct a reasonable investigation regardless of the post-investigation discovery that no loss had occurred. Defendant seeks an ex post facto ruling that their investigation and denial were per se reasonable because it later turned out that no theft had occurred in the first place-the law does not entitle them to that.

Furthermore, the entire case rests on the issue of the "reasonableness" of Defendant's investigation, which in turn rests on allegations that Thielbar the investigator either misrepresented (or, as Plaintiffs later argue, misconstrued or ignored) evidence favorable to Plaintiffs. This is very much a "what did Defendant's investigators know and when did they know it" case and (as detailed above) there are disputed issues of material fact in that regard (with Ethier claiming he told Thielbar one thing, and Thielbar claiming that he does not remember it that way). In the face of these disputed and material factual issues, summary judgment is not possible on most of these causes of action (with the exception of the equitable estoppel claim; see infra ).

On its face, Defendant has a stronger argument in its position that it is entitled to summary judgment because Plaintiffs *1234have not established any harm as a result of Defendant's conduct. However, Washington case law is against them: even the de minimis amount expended by Plaintiffs for their jewelry expert qualifies as "harm" according to the Washington Supreme Court.

Analysis of harm for every cause of action must begin from the undisputed fact that the only loss claimed to have been suffered by Plaintiffs is (1) the money they paid a jewelry expert-in preparation for litigation-for his opinion regarding the amount of time it would take to swap out the diamond ($420; Dkt. Nos. 21-8 and 21-9), and (2) their attorneys' fees.

A seminal "bad faith harm" case is Coventry v. American States Ins. Co.

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Bluebook (online)
319 F. Supp. 3d 1227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wall-v-country-mut-ins-co-wawd-2018.