X v. Progressive Direct Insurance Company

CourtSuperior Court of Delaware
DecidedNovember 22, 2024
DocketN23A-05-008 VLM
StatusPublished

This text of X v. Progressive Direct Insurance Company (X v. Progressive Direct Insurance Company) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
X v. Progressive Direct Insurance Company, (Del. Ct. App. 2024).

Opinion

SUPERIOR COURT OF THE STATE OF DELAWARE VIVIAN L. MEDINILLA LEONARD L. WILLIAMS JUSTICE CENTER JUDGE 500 NORTH KING STREET, SUITE 10400 WILMINGTON, DELAWARE 19801-3733 TELEPHONE: (302) 255-0626

Submitted: August 21, 2024 Decided: November 21, 2024

George X Matthew E. O’Byrne, Esquire 301 Bayard Street Daniella C. Spitelli-Sarnecky, Esquire P.O. Box 46 Casarino Christman Shalk Delaware City, DE 19706 Ransom & Doss, P.A. 1000 North West Street, Suite 1450 Wilmington, DE 19899

RE: George X v. Progressive Direct Insurance Company C.A. No.: N23A-05-008 VLM

Dear Messrs. X and O’Byrne,

This matter is Appellant, Mr. X’s, de novo appeal against Respondent

Progressive Direct Insurance Company. Trial is scheduled for February 10, 2025

against Respondent Progressive Direct Insurance. Before the Court are cross

Motions for Summary Judgment from the parties. For the reasons stated below, Mr.

X’s Motion is DENIED, and Progressive’s Motion is GRANTED.

1 I. RELEVANT FACTS AND PROCEDURAL HISTORY1

A. THE INSURANCE POLICY On March 22, 2022, George X (“Mr. X”) renewed his comprehensive

automobile insurance policy with Progressive Direct Insurance Company

(“Progressive”), paying a six-month premium for comprehensive and collision

coverage, which included rental reimbursement coverage (“the Policy”).2

The Policy provides: “If you pay the premium for this coverage, we will pay

for sudden, direct and accidental loss to a: (1) covered auto...; and its custom parts

or equipment, that is not caused by collision.”3 Under the comprehensive coverage,

covered losses include “malicious mischief or vandalism” and “theft or larceny.”4

If determined to be a covered loss, the Policy also provides rental coverage.5

The Policy, however, contains exclusions. It states: “Coverage under this Part

IV will not apply for loss… to any vehicle that is due and confined to. . . wear and

1 Unless otherwise noted, this Court’s recitation is drawn from the Notice of Appeal (“Appeal”) and all documents the parties incorporated by reference. D.I. 1. 2 Progressive Direct Insurance Company’s Motion for Summary Judgment, D.I. 83 (hereinafter “Progressive’s Mot.”), Ex. B at 19 (hereafter “Auto Policy”). 3 Id. 4 Id. 5 Id. at 20. The rental coverage provides “We will reimburse rental charges incurred when you rent an auto from a rental agency or auto repair shop due to a loss to a covered auto for which Rental Reimbursement Coverage has been purchased. This coverage applies only if you have purchased both Comprehensive Coverage and Collision Coverage for that covered auto and the loss is covered under one of those coverages.”

2 tear. . . , [or] mechanical, electrical or electronic breakdown or failure. . . .”6 But the

exclusion “does not apply if the damages results from the theft of a vehicle.”7

B. THE CLAIM AND INVESTIGATION On June 12, 2022, around 1:00 a.m., Mr. X discovered damage to his 2015

Hyundai Accent that was parked in front of his home in Delaware City.8 Mr. X called

911, and Delaware City Police Tyler Gaul responded, documenting in an Initial

Crime Report that Mr. X was “the victim of vandalism.”9 Mr. X filed a claim with

Progressive that same day, reporting that the vehicle had been keyed, had a white

substance around the gas tank area, and would not start.10 Mr. X also discovered the

vehicle had been moved from its original parking location.11

Progressive arranged for the vehicle to be towed to Bud’s Automotive (later

renamed “Steadfast Automotive”).12 On June 14, 2022, Progressive provided Mr. X

with a rental vehicle under the Policy’s rental reimbursement provision.13 On June

16, 2022, Steadfast Automotive conducted an inspection that revealed various

6 Id. at 22. 7 Id. 8 Mr. X’s Motion for Summary Judgment ¶ 21, D.I. 66 (hereinafter “Mr. X’s Mot.”). 9 Id. ¶ 21-22. 10 Progressive’s Mot. at 4. 11 Id., Ex. E. 12 Progressive’s Mot., Ex. D. 13 Id.

3 mechanical issues, including problems with the engine and electrical systems.14 On

June 20, 2022, further inspection revealed the vehicle had been keyed and a blown

head gasket causing coolant to mix with engine oil, along with various engine codes

and a hydro-locked engine.15

On June 28, 2022, Progressive issued a Reservation of Rights Letter and

discontinued rental coverage pending investigation of whether the damages were

covered under the Policy.16 Following the Letter, Progressive made repeated

attempts to obtain additional information and documentation from Mr. X. Between

July 2022 and May 2023, Progressive sent at least sixteen letters requesting Mr. X’s

cooperation with the investigation, including requests for service records and

authorization for additional testing.17

In September 2022, Armstrong Forensic Laboratory tested fluid samples from

the vehicle and concluded the engine issues were consistent with wear and tear rather

than vandalism.18 On January 6, 2023, Progressive issued payment for the

undisputed exterior damage to the vehicle.19

14 Progressive’s Mot., Ex. H. 15 Progressive’s Mot., Ex. D. 16 Progressive’s Mot., Ex. I. 17 See Progressive’s Mot., Exs. J, M, N, P, R-U, W-Z, AA. 18 Progressive’s Mot., Ex. Q. 19 Progressive’s Mot. at 12.

4 C. PROCEDURAL HISTORY On February 27, 2023, Mr. X filed for arbitration with the Delaware

Department of Insurance.20 A hearing was held On May 10, 2023, before the

Department of Insurance Automobile Arbitration Panel which found in Progressive's

favor, holding Mr. X needed to “submit appropriate testing from his mechanic

showing the engine damage is related to the vandalism.”21

Following the Panel’s decision, Mr. X initiated this action by filing a “Notice

of Appeal” on May 23, 2023.22 He subsequently filed a two-page Amended Notice

of Appeal on June 7, 2023, alleging violations of the Motor Vehicle Owners’ Right

to Repair Act, breach of contract, and loss of potential earnings.23

Through an unopposed Motion to Amend, Mr. X sought to have the Court

accept the initial pleading as a Complaint and amend his claims to nine pages.24 This

Amended Complaint substantially broadened the scope of allegations to include: (1)

bad faith breach of duty to indemnify; (2) bad faith undermining of the police report;

(3) bad faith tactics regarding rental coverage; and (4) bad faith delay in investigation

20 Id. 21 See Appeal. 22 Id. 23 D.I. 17. 24 The Amended Complaint is included in the exhibits. See D.I. 24, Exhibits.

5 and repair.25 Adding to his claims, and without opposition, Mr. X supplemented his

Amended Complaint with a Letter of Demand, this time requesting $600,000 in lost

earnings.26

Respondent filed its Answer, and the Court issued its Trial Scheduling Order

in September 2023.27 The parties issued written discovery and Mr. X was deposed.28

On February 13, 2024, Progressive filed a Motion to Compel an Expert Report

to opine on causation related to engine failure.29 Because Mr. X argued his theory

of liability was no longer based on the engine’s failure but rather on supposed

contractual failures on the part of Progressive, this Court denied the Motion to

Compel.30

Mr. X continued to complicate the procedural path by filing multiple

amendments and supplements to his Amended Complaint,31 even after the discovery

25 Id. 26 D.I. 26. In the Letter of Demand, Mr.

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X v. Progressive Direct Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/x-v-progressive-direct-insurance-company-delsuperct-2024.