Washington Cities Insurance Authority v. Ironshore Indemnity Inc

CourtDistrict Court, W.D. Washington
DecidedMarch 6, 2020
Docket2:19-cv-00054
StatusUnknown

This text of Washington Cities Insurance Authority v. Ironshore Indemnity Inc (Washington Cities Insurance Authority v. Ironshore Indemnity Inc) 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
Washington Cities Insurance Authority v. Ironshore Indemnity Inc, (W.D. Wash. 2020).

Opinion

The Honorable Richard A. Jones 1

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 WASHINGTON CITIES INSURANCE 9 AUTHORITY, 10 No. 2:19-cv-0054-RAJ

11 Plaintiff, 12 v. ORDER DENYING MOTION TO COMPEL ARBITRATION 13 AND ESTABLISHING CHOICE IRONSHORE INDEMNITY, INC., OF LAW AND ARBITRATION 14 PROVISIONS AS VOID 15 Defendant.

16 17 This matter is before the Court on Defendant’s motion to compel arbitration (Dkt. 18 # 20) and Plaintiff’s motion to establish the choice of law and arbitration provisions as 19 void. (Dkt. # 17). For the following reasons, Defendant’s motion to compel is DENIED. 20 Dkt # 20. Plaintiff’s motion is GRANTED. Dkt. # 17. 21 I. BACKGROUND 22 Plaintiff Washington Cities Insurance Authority (“WCIA”), is “an association of 23 Washington public entities organized under and authorized by RCW § 48.62 for the 24 purpose of jointly self-insuring risks, jointly purchasing insurance or reinsurance, and 25 contracting for joint risk management, claims and administrative services.” Dkt. # 1 at ¶ 26 1.1. WCIA alleges that it entered into a contract with Defendant Ironshore Indemnity 1 (“Ironshore”), whereby Ironshore agreed to provide reinsurance up to $10 million “per 2 occurrence” for losses exceeding WCIA’s $4 million self-insured layer limit. Dkt. # 1 at 3 ¶ 3.3. The Agreement includes an arbitration provision which states, in part: “Any and 4 all disputes or differences arising out of this Agreement, including its formation and 5 validity, shall be submitted to binding arbitration.” Dkt. # 19 at 9. The Agreement also 6 includes a New York choice of law provision. Id. 7 The underlying claim at issue in this case arises from a 2018 settlement related to 8 a separate police misconduct lawsuit. Dkt. # 17 at 3. According to WCIA, the 9 settlement fell within Ironshore’s reinsurance policy but Ironshore refused to pay. Id. 10 Ironshore’s denial of coverage is the basis for Plaintiff’s suit. Dkt. # 1. The parties also dispute the applicability of the arbitration and choice of law provisions in the 11 Agreement. WCIA moves to void the provisions as prohibited under Washington law. 12 Dkt. # 17. Ironshore separately moves to compel arbitration. Dkt. # 20.1 13 II. LEGAL STANDARD 14 Because the Federal Arbitration Act (“FAA”) requires courts to “direct the 15 parties to proceed to arbitration on issues as to which an arbitration agreement has been 16 signed, the FAA limits court involvement to determining (1) whether a valid agreement 17 to arbitrate exists and, if it does, (2) whether the agreement encompasses the dispute at 18 issue.” Cox v. Ocean View Hotel Corp., 533 F.3d 1114, 1119 (9th Cir. 2008) (internal 19 quotations omitted). The party opposing arbitration bears the burden of showing that the 20 agreement is not enforceable. See Green Tree Fin. Corp. v. Randolph, 531 U.S. 79, 91- 21 22 23

24 1 Ironshore also moves to strike three exhibits that it argues were improperly filed with 25 WCIA’s reply brief (Dkt. # 25). Dkt. # 28. Ironshore’s motion to strike is GRANTED. Nautilus Grp., Inc. v. Icon Health & Fitness, Inc., 308 F. Supp. 2d 1208, 1214 (W.D. 26 Wash. 2003), aff'd, 372 F.3d 1330 (Fed. Cir. 2004) (striking new evidence submitted for 1 92 (2000); Rodriguez de Quijas v. Shearson/American Exp., Inc., 490 U.S. 477, 483 2 (1989). 3 “The FAA limits the district court’s role to determining whether a valid 4 arbitration agreement exists, and whether the agreement encompasses the disputes at 5 issue.” Nguyen v. Barnes & Noble Inc., 763 F.3d 1171, 1175 (9th Cir. 2014) (internal 6 citation omitted). To determine “whether a valid arbitration agreement exists, federal 7 courts ‘apply ordinary state-law principles that govern the formation of contracts.’ ” Id. 8 (quoting First Options of Chi., Inc. v. Kaplan, 514 U.S. 938, 944 (1995)). In 9 determining whether an arbitration agreement encompasses the dispute at issue, district 10 courts must be mindful that “arbitration is a matter of contract and a party cannot be required to submit to arbitration any dispute which he has not agreed so to submit.” 11 AT&T Technologies, Inc. v. Commc’ns Workers of Am., 475 U.S. 643, 648, 106 S. Ct. 12 1415, 89 L.Ed.2d 648 (1986). Any doubts as to the scope of an arbitration agreement 13 should be resolved in favor of arbitrability. Simula v. Autoliv, 175 F.3d 716, 721 (9th 14 Cir. 1999). 15 III. DISCUSSION 16 At issue in this case is Washington’s prohibition on the use of arbitration and 17 choice of law provisions in insurance contracts. Washington law bars the enforcement 18 of binding arbitration clauses in insurance contracts. See State, Dep’t of Transp. v. 19 James River Ins. Co., 176 Wash. 2d 390, 399 (2013) (interpreting RCW 20 48.18.200(1)(b)). Although the FAA would normally preempt a conflicting state law 21 under the Supremacy Clause, the McCarran-Ferguson Act creates a system of “reverse- 22 preemption” for insurance law. See United States Dep’t of Treasury v. Fabe, 508 U.S. 23 491, 501 (1993). Under McCarran-Ferguson, “No Act of Congress shall be construed to 24 invalidate, impair, or supersede any law enacted by any State for the purpose of 25 regulating the business of insurance ... unless such Act specifically relates to the business 26 1 appear to dispute, that under the McCarran-Ferguson Act, RCW 48.18.200 preempts 2 Chapter I of the FAA. See James River, 176 Wash. 2d at 402; Landmark Am. Ins. Co. v. 3 QBE Ins. Corp., No. C15-1444 RSM, 2015 WL 12631550, at *6 (W.D. Wash. Dec. 9, 4 2015). 5 WCIA argues that the arbitration and choice of law provisions in the Agreement 6 violate Washington’s arbitration exclusion, rendering them void. Ironshore contends 7 that the Agreement is not an “insurance” agreement under RCW § 48.01.040 and thus 8 not subject to the anti-arbitration provision. In addition, Ironshore argues that a separate 9 provision regulating the purchase of coverage by joint self-insurance programs, preempts 10 the anti-arbitration prohibition, rendering the parties’ arbitration and choice of law provisions permissible. Dkt. # 20 at 11-12. 11 There are two key questions that the Court must answer in this case: (1) does 12 “reinsurance” qualify as “insurance” and (2) does the anti-arbitration provision in RCW 13 § 48.18.200 apply to reinsurance agreements where the reinsurance coverage is 14 purchased by a joint self-insurance program. The answer to both questions is yes. 15 A. Reinsurance is Insurance under RCW § 48.01.040

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Washington Cities Insurance Authority v. Ironshore Indemnity Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-cities-insurance-authority-v-ironshore-indemnity-inc-wawd-2020.