Westboro Condominium Association v. Country Casualty Insurance Company

CourtDistrict Court, W.D. Washington
DecidedJanuary 11, 2023
Docket2:21-cv-00685
StatusUnknown

This text of Westboro Condominium Association v. Country Casualty Insurance Company (Westboro Condominium Association v. Country Casualty Insurance Company) 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
Westboro Condominium Association v. Country Casualty Insurance Company, (W.D. Wash. 2023).

Opinion

1 The Honorable Barbara J. Rothstein

5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE

7 NO. 2:21-cv-685 WESTBORO CONDOMINIUM 8 ASSOCIATION, a Washington Non-Profit ORDER: (1) DENYING PLAINTIFF’S Corporation, MOTION FOR SANCTIONS; (2) 9 Plaintiff, DENYING DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT; and (3) 10 v. GRANTING IN PART AND DENYING IN PART PLAINTIFF’S MOTION FOR 11 COUNTRY CASUALTY INSURANCE SUMMARY JUDGMENT COMPANY, et al., 12 Defendants. 13

14 I. INTRODUCTION 15 This matter comes before the Court on cross Motions for Summary Judgment, filed by 16 Plaintiff Westboro Condominium Association (the “Association”) and Defendants Country 17 Casualty Insurance Company and Country Mutual Insurance Company (collectively, “Country” 18 or “Defendants”). Dkt. Nos. 23 & 26. The Association seeks a declaratory judgment on its claim 19 on a Country all-risk insurance policy, for hidden water damage to the framing and sheathing at 20 the Westboro Condominiums. Country seeks dismissal of the Association’s claims based on the 21 “known risk” affirmative defense, asserting that the Association knew of the damage when it 22 23 ORDER

24 - 1 1 purchased its policy. After Country filed its motion two weeks past the dispositive motions 2 deadline, Plaintiff also filed a Motion for Sanctions, asking the Court to strike Country’s motion. 3 Dkt. No. 28. Having reviewed the parties’ briefs, the supporting declarations and exhibits, and the 4 relevant caselaw, the Court finds and rules as follows. 5 II. BACKGROUND 6 This lawsuit concerns a claim the Westboro Condominium Association submitted in 7 January 2020 on its all-risk insurance policy, issued by Country for the period August 2018-

8 August 2019. The claim is for repairs for water damage to framing and sheathing at the Westboro 9 Condominiums buildings. The Westboro Condominiums, built in 1980, “consists of seventeen 10 (17) two-story, wood framed, residential buildings, with a total of 68 units, located in Federal 11 Way, Washington. . . . The exterior wall consists of [cedar] siding, over weather resistive barrier 12 (“WRB”) over ThermoPly structural sheathing and pressboard sheathing, and framing. The 13 framing is hidden from view by the sheathing, the sheathing is hidden from view by the WRB and 14 the WRB is hidden from view by the siding.” Compl. ¶ 2.1; Pl.’s Mot. at 5 (citing Eggert Decl.). 15 In December 2019, the Association commissioned an intrusive investigation into the 16 buildings’ condition, involving opening the layers of the envelope down to the framing. Eleven of 17 the twelve openings performed in the investigation revealed hidden water damage to the

18 buildings’ framing and sheathing. Eggert Decl., ¶ 8. After the Association submitted its claim to 19 Country (and other insurers), the parties conducted a joint investigation in June 2020, which 20 confirmed that there was water damage to the framing and sheathing throughout the Westboro 21 Condominiums. The cause of the damage, according to Plaintiff’s expert, was intrusion of water 22 resulting from a combination of inadequate construction and wind-drive rain. Eggert Decl., ¶ 22. 23 ORDER

24 - 2 1 Country denied the Association’s claim in December 2020, leading to the filing of this lawsuit. 2 3 4 5 6 7

8 9 10 11 12 13 14 15 16 17

18 19 20 21 22 23 ORDER

24 - 3 1 III. DISCUSSION 2 A. Plaintiff’s Motion for Sanctions

3 In May 2022, the parties jointly moved for an extension of several pretrial deadlines, 4 including the dispositive motions deadline. The Court granted that motion in part, but explicitly 5 directed the parties to “[n]ote that the Court has set a Dispositive Motions Deadline of August 8, 6 2022, not August 22, 2022 as the parties requested.” Order at 2, Dkt. No. 22. The Association 7 filed its Motion for Summary Judgment on August 8, 2022. The Defendant, however, did not file 8 its Motion until August 22, 2022. 9 Three days later, Plaintiff filed a motion seeking sanctions for Defendants’ late filing, 10 asking the Court to strike Defendants’ motion. As Plaintiff argues, Court-ordered deadlines are 11 “firm” and not to be modified without a showing of good cause. The “good cause” that 12 Defendants claim is that the parties had in fact requested an August 22 deadline, and it simply 13 erred in assuming the Court’s order adopted that date. 14 Generally, a calendaring error is not “good cause” that justifies missing a deadline. In this 15 case, however, the Court declines to strike Defendants’ late-filed Motion for Summary Judgment. 16 Plaintiff has not claimed it has suffered any prejudice from the late filing. Nor does Plaintiff claim 17 that the Defendants acted in bad faith or gained any particular advantage in filing the motion late,

18 and it appears this is its first missed deadline in this case. Furthermore, the interests of judicial 19 economy are served by having the Court consider and resolve any potentially dispositive issues of 20 law before trial. Plaintiff’s Motion for Sanctions is therefore denied. 21 B. Motions for Summary Judgment: Standard 22 “Summary judgment is appropriate when, viewing the evidence in the light most favorable 23 ORDER

24 - 4 1 to the nonmoving party, there is no genuine dispute as to any material fact” and the movant is 2 entitled to judgment as a matter of law. Zetwick v. County of Yolo, 850 F.3d 436, 440 (9th Cir. 3 2017) (quoting United States v. JP Morgan Chase Bank Account No. Ending 8215, 835 F.3d 4 1159, 1162 (9th Cir. 2016)); Fed. R. Civ. P. 56(a). “The moving party bears the initial burden of 5 identifying portions of the record that demonstrate the absence of a fact or facts necessary for one 6 or more essential elements of each claim.” InteliClear, LLC v. ETC Glob. Holdings, Inc., 978 7 F.3d 653, 657 (9th Cir. 2020). “If the moving party meets this burden, the opposing party must

8 then set out specific facts showing a genuine issue for trial to defeat the motion.” Id. If the 9 evidence proffered by the opposing party “is merely colorable, or is not significantly probative, 10 summary judgment may be granted.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249-50 11 (1986) (citations and quotation marks omitted). 12 C. Defendants’ Motion for Summary Judgment

13 By their Motion for Summary Judgment, Defendants move the Court for a ruling that 14 Plaintiff’s lawsuit is barred by the “known loss” doctrine, also referred to as the “fortuity 15 principle.” The notion is that “an insured cannot collect on an insurance claim for a loss that the 16 insured subjectively knew would occur at the time the insurance was purchased.” MKB 17 Constructors v. Am. Zurich Ins. Co., 49 F. Supp. 3d 814, 838 (W.D. Wash. 2014) (citing 18 Hillhaven Props. Ltd. v. Sellen Constr. Co., Inc., 133 Wn. 2d 751 (1997)). Typically, “whether a 19 particular occurrence was expected by the insured before the insurance coverage was obtained ... 20 is a question of fact.” Pub. Util. Dist. No. 1 of Klickitat Cnty. v. Int’l Ins. Co., 124 Wn.2d 789 21 (1994); see also Frank Coluccio Constr. Co., 150 P.3d at 1156 (“The test for fortuity is a 22 subjective, not objective, one, and involves questions of fact.”). 23 ORDER

24 - 5 1 Defendants rely on several documents in support of their claim that the Association was 2 aware of damage to the framing and sheathing at the time it purchased the Country policy in 3 August 2018.

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Westboro Condominium Association v. Country Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/westboro-condominium-association-v-country-casualty-insurance-company-wawd-2023.