Wright v. State Farm Fire & Casualty Company

District Court, W.D. Washington·Decided January 21, 2025·No. 2:23-cv-00179·Unknown

Opinion

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3 4 5 UNITED STATES DISTRICT COURT AT SEATTLE 7 MICHAEL WRIGHT; ALEXIS CASE NO. 2:23-cv-179 ORDER DENYING PLAINTIFFS’ 9 Plaintiffs, MOTION TO EXCLUDE 10 v. COMPANY, 12 Defendant. 13

14 1. INTRODUCTION 15 Plaintiffs Michael and Alexis Wright (the “Wrights”) move to exclude the 16 testimony of Defendant State Farm Fire and Casualty Company’s (“State Farm”) 17 construction and repair expert, Eugene Peterson. Dkt. No. 90. Having reviewed the 18 record, the parties’ briefing, and the law, and being fully informed, the Court, for 19 the reasons explained below, DENIES the motion to exclude. 20 2. BACKGROUND 21 In November 2021, a fire caused severe damage to the Wrights’ home, located 22 in Goldendale, Washington, a rural area about 70 miles from Yakima, Washington. 23 1 Dkt. No. 89-1 at 2. The Wrights filed a claim with their insurer, State Farm, which 2 immediately confirmed coverage. Id.

3 In January 2022, the adjuster assigned to the Wrights’ file, Timothy Treat, 4 finalized his initial estimate for the structural repair of the Wrights’ home. Dkt. No. 5 89-6 at 7-9. To do so, he used a software called Xactimate, which uses data on labor 6 and material costs to estimate total repair costs. Id. Xactimate yielded an estimate 7 for the Wrights’ home repair in the amount of $181,277.82. Id. 8 According to the Wrights, because they lived in Goldendale, a rural location,

9 it took them several months to find a contractor willing to perform the repair. Dkt. 10 No. 89-2 at 11. By June 2022, they found a company willing to do the work for an 11 estimated total cost of $259,244.61—nearly $80,000 above State Farm’s Xactimate 12 estimate. Dkt. No. 89-1 at 49. 13 In November 2022, after extensive back-and-forth, the Wrights brought 14 contractual and extracontractual claims against State Farm, alleging that State 15 Farm failed to properly investigate and cover their losses. Dkt. No. 1. Among other

16 arguments, the Wrights assert that State Farm uses Xactimate, which “is designed 17 with input and pricing data primarily sourced from the insurance industry,” to 18 intentionally achieve “cost containment.” Dkt. No. 88 at 17. 19 At trial, State Farm intends to offer opinion testimony from construction and 20 repair expert Eugene Peterson “regarding [among other topics] the reasonableness 21 of State Farm’s use of Xactimate to create repair estimates in this matter.” Dkt. No.

22 102 ¶ 1. Peterson has worked with the Xactimate since 1991, including beta testing 23 1 new iterations of the program, training contractors on how to use the software, and 2 creating the first online Xactimate training syllabus. Id. ¶¶ 2-3.

3 In January 2024, Peterson submitted an expert report rebutting the report of 4 the Wrights’ expert, Al Meads. Dkt. No. 91-1. Meads, opining that State Farm’s 5 repair estimate was too low, stated in his report that “State Farm estimates are 6 written using the price lists from Yakima, Washington, which is over 70 miles from 7 the loss location [in Goldendale].” Id. at 3. Meads also stated that “the pricing is 8 based on using a ‘big box’ store for the materials,” but that “[s]ince there are no such

9 outlets in Goldendale…, there will be additional cost either from buying locally from 10 a local vendor, or incurring the costs in time and production by traveling to one of 11 these outlets.” Id. In his rebuttal, Peterson stated that Meads’s assertions were 12 technically “true”—“the regional price list expected to be used for the Goldendale, 13 WA area is the Yakima, Washington price list”—but that “[t]he adjuster chose and 14 applied an option found in the Xactimate estimating software for rural settings to 15 account for the rural location.” Id. Peterson explained, “[w]hen this option is

16 applied, the software automatically factors and applies additional dollars to each 17 line item to account for the increased labor and materials costs and the difficulty of 18 working in a rural setting.” Id. Likewise, Peterson stated that this “‘rural/remote’ 19 setting factors in some of the difficulties of material accusation [sic], by bumping 20 pricing of materials so that purchase can be made locally.” Id. 21 But Peterson may have been wrong about Treat applying the “rural/remote”

22 setting when estimating the Wrights’ repair costs. When Treat was asked during 23 his deposition whether he was familiar with the “site access” drop-down feature, he 1 testified, “I have not seen this.”1 Likewise, when Peterson was deposed in October 2 2024, he admitted that he “cannot say for certainty that [Treat] did [use the

3 “rural/remote” feature].” Dkt. No. 91-2 at 5. 4 The Wrights now move to exclude Peterson’s expert testimony, arguing that 5 Peterson’s mistaken claim that Treat used the “rural/remote” feature renders 6 Peterson’s opinion testimony “unsubstantiated, speculative, lack[ing] foundation, 7 amount[ing] to legal opinions, and otherwise [ ] not comport[ing] with Fed. R. Evid. 8 702 and 703.” Dkt. No. 90 at 1.

9 3. DISCUSSION 10 3.1 Legal standard. 11 Rule 702 of the Federal Rules of Evidence governs the admission of expert 12 opinion testimony in federal court: 13 A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise 14 if the proponent demonstrates to the court that it is more likely than not that: (a) the expert’s scientific, technical, or other specialized knowledge 15 will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the 16 testimony is the product of reliable principles and methods; and (d) the expert’s opinion reflects a reliable application of the principles and 17 methods to the facts of the case.

18 Fed. R. Evid. 702. Rule 702 is to be applied with a “liberal thrust favoring 19 admission, [but] it requires that expert testimony be both relevant and reliable.” 20 21 1 The Court notes, however, that this deposition testimony lacks support in the 22 record. The Wrights cite to “Derenski Decl., Ex. 3, 72:21-73:8.” Dkt. No. 90 at 4. However, those deposition pages are not attached with the excerpts from Treat’s 23 deposition at Dkt. No. 91-3. 1 Messick v. Novartis Pharms. Corp., 747 F.3d 1193, 1196 (9th Cir. 2014) (cleaned 2 up). “Expert opinion testimony is relevant if the knowledge underlying it has a valid

3 connection to the pertinent inquiry. And it is reliable if the knowledge underlying it 4 has a reliable basis in the knowledge and experience of the relevant discipline.” 5 United States v. Sandoval-Mendoza, 472 F.3d 645, 654 (9th Cir. 2006) (emphasis 6 added) (quotation marks and citation omitted). The proponent of expert testimony 7 bears the burden of establishing relevance and reliability. Daubert v. Merrell Dow 8 Pharms., Inc., 43 F.3d 1311, 1316 (9th Cir. 1995). When this burden is met, “the

9 expert may testify and the jury decides how much weight to give that testimony.” 10 Primiano v. Cook, 598 F.3d 558, 565 (9th Cir. 2010), as amended (Apr. 27, 2010).

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