hillerich & bradsby co. v. ace american insurance company complaint

8/3/2019 HILLERICH & BRADSBY CO. v. ACE AMERICAN INSURANCE COMPANY Complaint

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Perry J. Schneider, Esq.ChrIstopher L. Decker, Esq. MILODRAGOVICH. DALE, STEINBRENNER& NYGREN, P.C. 620 High Park WayP.O. Box 4947Missoula, Montana 59806-4947.Telephone: (406) 728-1455Fax No: (406) 549-7077E : M a i . ~ I : f f ~ ~ ~ ~ ~ ~ ~ ~ ~

IN TIIE UNITED STATES DISTRICT COURTFOR TIIE DISTRICT OF MONTANA

HELENA DMSIONHlLLERICH & BRADSBY CO.,

Plaintiff,-vs-

ACE AMERICAN INSURANCECOMPANY,

Defendant.

Cause No.Q\I- I \ 15 11 DWMDEFENDANT'S NOTICE OFREMOVAL

Defendant, ACE American Insurance Company ("Defendant"), pursuant to28 U.S.C. 1441, gives notice ofremoval with respect to Case No. BDV 2011909 pending in the Montana First Judicial District Court, Lewis & Clark County,,and states that removal to the Federal Court is proper for the following reasons:

1. On or about November 15,2011, an Amended Complaint was filedby Plaintiff against Defendant in the Montana First Judicial District Court, Lewisand Clark County, Cause No. BDV 2011-909.

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2. On November 15,2011, Defendant, through the Montana InsuranceCommissioner, received a copy of the Summons and Amended Complaint in theabove action. Copies of the Amended.Summons and Amended Complaint areattached hereto as Exhibits A and B. Prior to that date, Defendant has notreceived, by service or otherwise, a copy of the summons and complaint filed inthe state court action.

3. Other than the documents attached as Exhibits A andB, Defendanthas not been served with any other pleadings, papers or orders in this action, andfewer than thirty days have elapsed since the initial pleading was received.

4. No other proceedings have been had in this action.5. Defendant seeks removal of this action, pursuant to 28 U.S.C.

144 I (b). This is a civil action over which this Court has original jurisdiction,pursuant to 28 U.S.C. 1332. It is a dispute between citizens of different statesand the amount in controversy exceeds $75,000, exclusive of interest and costs.

7. Plaintiffwas at the time of the commencement of this action, and isnow, a Kentucky corporation, being formed in the state ofKentucky, and havingits principal place ofbusiness in Louisville, Kentucky. Defendant was at the timeof the commencement of this action, and is now, aPermsylvania corporation,being formed in the state ofPennsylvania, and having its principal places ofbusiness in Philadelphia, Pennsylvania. As a result, for purposes of28 U.S.C. 1332(a), there is complete diversity ofcitizenship between the parties. See 28U.S.c. 1332(cXl).

8. . Plaintiff's Complaint asserts three causes ofaction: Breach ofContract, Declaratory Judgment, and Violations ofMont. Code Ann. 33-18-201.

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Plaintiff alleges that Defendant breached the provisions of an insurance policy itissued Plaintiff and seeks, as damages, certain attorney fees and costs Plaintiffincurred in an underlying matter, including fees and costs for appealing the verdictin that case. Plaintiff seeks other contract damages, and compensatory andpunitive damages under Montana's unfair claims settlement practices statutes.Defendant believes therefore, and avers, that the amount in controversy exceeds$75,000 based on the claims and the damages Plaintiff seeks.

9. This Notice ofRemoval is filed timely with this Court pursuant to 28U.S.c. 1446(b), because thirty days have not expired since this action becameremovable to this Court.

10. Pursuant to 28 U.S.C. 1446(d), written notice of the filing of thisNotice ofRemoval will be given to counsel for Plainti:r:t: and a copy of the NoticeofRemoval will be filed with the Clerk of the Montana First Judicial DistrictCourt, Lewis and Clark County.

WHEREFORE, Defendantprays that the United States District Court forthe District ofMontana, Helena Division, accept this Notice ofRemoval andassume jurisdiction ofthis cause and that it issue such further orders and processesas may be necessary to bring before it all parties necessary for the trial hereof.

DATED this 14th day ofDecember, 2011.

B Y : _ " ; - I " , , s / - , P , " : , e ~ n : : y , * " " J T ' .",S;chnTe""id,.,e""r____Perry J. SchneiderMILODRAGOVICH, DALE,STEINBRENNER & NYGREN, P.C.Attorneys for Defendant3



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Kyle Anne GrayJason S. RitchieHOLLAND & HART LLP401 North 31st Street, Suite 1500P.O. Box 639Billings, Montana 59103-0639Telephone: (406) 252-2166Fax: (406) 252-1669ATTORNEYS PLAINTIFF

MONTANA FIRST JUDICIAL DISTRICT COURT LEWIS & CLARK COUNTY, MONTANA Hillerich & Bradsby Co., ) No. BDV 2011-909)

Plaintiff, ) Judge Jcffrey M. Sherlock)v. )) AMENDED COMPLAINT ANDACE American Insurance Company, )) DEMAND FOR JURy TRIALDefendant. )

Plaintiff, by and through its counsel of record, Holland & Hart LLP, for its AmendedComplaint against Defendant, alleges and states as follows:

PARTIES1. Hillerich & Bradsby Co. (H&B") is a corporation that manufactures, inter alia,

baseball bats under the trademark of Louisville SlUgger. .2. ACE American lnsurance Company ( " A C E ~ ' ) is a corporation engaged in the

business of insurance in, among other places, the State of Montana.

R f , C ~ \ \ , e o NO\l 2 S lOll

ACe. INCmJnNG LEGALEXHIBIT B

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JURISDICTION AND VENUE 3. Jurisdiction for this action is proper with this Court because the insured accident

in issue occurred in Montana, because judgment was awarded against H&B and satisfied inMontana, and because Montana is the place ofperformance of the subject insurance policy.

. : : : ! 4 ~ . Yenuefor thisaction is proper with this Collrt under 25-2-122(2), MeA,because the insured accident in issue occurred in Lewis & Clark County, Montana, because thesubject insurance policy was partially performed in Lewis & Clark County, and becausejudgment was obtained against H&B in Lewis & Clark County.

GENERAL ALLEGATIONS TOALL COUNTSThe Patch Case.5. In July 2003, Brandon Patchwas ii!jnred in an American Legion baseball game in

Helena, Montana, and later died from his injuries.6. Brandon Patch's Estate, and his mother, Debbie Patch, as personal representative,

brought suit against H&B in Cause No. ADV 2006-397 (later transferred to CDV 2006-397).7. In order to defend against the claims in the Patch suit, H&B hired counsel in

Montana. Through discovery, motion practiee and pretrial preparation, H&B incurred and paidattorney fees and costs in Montafl"a related to its defense against the claims in the Patch case, inan amount that by the date of trial in October 2009 exceeded .$350,000.

8. The claims of the Patch plaintiffs were tried before ajury in this Court in October,2009. The Patch plaintiffs argued that one ofH&B's products, a metal baseball bat, was adefectively designed product, or alternatively that H&B did not properly warn the Patchplaintiffs about the product.

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9. On October 28, 2009, a verdict for $850,000 was rendered for the Patch plaintiffsand against H&B in Cause No. CDV 2006-397 on the Patch plaintiffs' products liability failureto warn claim. The Pa:tchjury also found H&B's bat product was not defectively designed.

10. Judgment for $850,000 plus post-judgment interest was entered on November 9,

11. While pleased that its product had not been found to have been defectivelydesigned, H&B decided it was an important to its business interests to seek reversal of the failureto warn verdict, inter alia, to protect the reputation of its products, and also because the verdict

. left lUlclear what warning the plaintiffs or jury believed the product should carry, or how such awarning could or should be conveyed to II non-user bystander, tha,t is, to a pitcher who nevertouched or saw the bat, and was always at least 60 feet away from the product and its user, thebatter on the other team.

12. At all times before and after the verdict was entered, H&B believed (andcontinues to believe) there were solid filctualand legal reasons why the failure to warn verdictwas not supported by the evidence and should, and would, be reversed with either judgment as amatter of law entered for H&B, or alternatively, a new trial ordered.

13. In November 2009, H&B filed timely post-trial motions in the district court for judgment as a matter oflaw, or for a new trial.

14. When its post-trial motions were subsequently denied, H&B then timely appealedthe verdict to the Montana Supreme Court, agam believing it had strong legal and factualgrounds upon which it should be granted judgment as a matter of law, or be granted a new trial,including, inter alia, the failure of the Patch plain1:ifIS to prove, under controlling Montanaprecedent ("the Riley case"), tha t the lack of a warning the decedent would never have seen

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caused his fatal injuries, and also the fact that no cause of action existed under Montana law forproducts liability failure to warn a bystander.

15. On July 21, 2011, the Montana Supreme Court affirmed the verdict against H&B,.inter alia, by distinguishing that Court 's earlier decision in Riley v. AmericanHonda MotorCompany, 259 Mont. 128, 856 P.2d 1 9 n 9 ( ) ~ a n d adopting a decedent's exception to the Rileycase that had been proffered by the dissent (but not adopted by the majority) in the Rileydecision. The Court also extended the claim of products liability failure to warn to non-userbystanders.

16. By refusing to overturn the verdict and issuing the opinion it did, the MontanaSupreme Court's "decision put [it] in a tiny minority of states that recognize some kind ofbystander failure to warn liability, which most agree is unworkable and contrary to the reality ofmodem commerce." See "Case Study: Patch v. Hillerich & Bradsby - Law 360.com (Aug. 15,2011).

R&D's Insurance Policy and Dispute with ACE.17. H&B is insured for the Patch case under a policy it purchased from ACE, issued

by ACE as Policy No. Gl8381916 (hereafter, "the Policy"). A copy of the Policy is attachedhereto as Exhibit A. H&B paid the requisite policy premium.

18. Asset forth in the Policy's "SelfInsured Retention with ALAE LimitsEndorsements," (hereafter, "ALAE Endorsement"), R&B and ACE contracted for R&B to besubject to a $350,000 ALAE Self Insured Retention (hereafter, "ALAE SIR") limit of$350,000,and a separate liability Self-Insured Retention (hereafter, Liability SIR) of $250,000.

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19. "ALAE," which is an abbreviation for "Allocated Loss Adjustment Expenses," isa term that includes such expenses and costs ofa lawsuit as attorney fees incurred for defenseand appeal, and interest on judgments pending appeaL

20. The ALAE Endorsement contains the following language: "When the insured's__~ l i " - a b ' - ' i l i t y is reasonably expected to exceed the 'Selflnsured Retention' stated in the Dec""l=ar"'B.t!::!o"'n"",____

we may request the insured to tender the remaining limits of the 'Self-Insured Retention' in orderto complete the settlement of such claim or 'suit.' The insured will not unreasonably withholdits consent to our request to tender remaining limits of the 'Self Insured Retention.'" Thislanguage means that the Policy is what is commonly referred to as a "consent policy," that theotherwise generai right of an insurer to settle a suit over the objection of its insured is thuslimited by the policy Janguage.

21. ACE originally accepted its duty to defend H&B in the Patch case under thePolicy, but did not become obligated to pay anything forH&B's preparation of its defense untilshortly before the October 2009 trial date when H&B's funded ALAE exhausted its ALAE SIR

22. Although ACE had fully supported trial of the Patch claims, once the ALAE SIRwas exhausted and ACE became liable to pay for H&B's attorney fees and other costs oftcialand any appeal, ACE began to push H&B to try and settle the Patch case shortly before trial wasto begin in October 2009. Throughout this dispute, despite H&B's requests, ACE neverprovided an analysis of what it believed H&B overlooked in preparing its defense of the Patchcase, or what compelling evidence plaintiffs offered that H&B did not objectively assess, or thatH&B's assessment was unreasonable.

23. After the verdict was entered against H&B, bya series of e-mails and telephonecalls, ACE insiSted that H&B must now tender its $250,000 SIR to ACE so it could settle the .

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case for the amount of the verdict. In those discussions, ACE, acting through its Claim ManagerDavid C. Zielinski, informed H&B that the Policy was not a "consent policy," and that ACEcould settle the claim at any time and then demand that H&B pay its $250,000 SIR to ACE.

24. H&B disagreed with ACE's interpretation of the policy language, which itbelicvil

26. . By Jetter dated November 17, 2009, ACE responded to H&B's November 13,2009 letter, and informed H&B, inter alia, as follows:

"The express terms of the policy do not afford H&B the right to withholdconsent to settlement under the circumstances presented in this case."

"ACE is not willing to re-try this case." ACE has the ' right and opportunity to assume from the insured the defense and control of any claim of 'suit' including any appeal,' [but] ACE does not opt to assume such control of this matter."

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"ACE recommends settlement in the amount of $850,000," whichplaintiffs ''have expressed their willingness" to accept. If H&B does not tender its SIR and settle the case (before decision on the

post-trial motions and any appeal) for $850,000 using its SIR and$600,000 from ACE, then "ACE's obligations under the policy for thisclaim will be limited as follows: (1) payment of$600,000, notwithstanding the potential recovery ofa higher amOlJllt should plaimiffsprevail in a subsequent proceeding, (2) cessation ofany obligation to payany ALAE following November 17,2009, (3) limitation on any interestobligation to that portion of ACE's payment under the policy and (4) noobligation to pursue or pay for any appeal." "ACE also reseI:Ves its rights to pay the entire amount of the judgment andseek recovery of the SIR from H&B. The actual course ofaction pursued

by ACE shall be at ACE's sole discretion.27. Despite ACE's threats, H&B decided to proCeed with its post-trial motion and

ultimately appeal. It incurred ALAE expenses for pursuing the post-trial motion, preparing aNotice ofAppeal, engaging in required pre-appeal mediation, and in securing a bond and a stayof the judgment pending appeal, in an amount sufficient to pay the judgment and statutory 10%annual post-judgment interest. ACE paid a portion ofH&B's appeal bond costs, but not theentire amount as required by the Policy.

28. ACE refused to pay any further ALAE incurred by H&B after November 17,2009, and spe\iifically instructed H&B to discontinue tendering such fees and costs to ACE for

. payment, which H&B did. H&B continued to incur and pay ALAE expenses, including payingfees to its counsel for post-trial practice, appeal and oral argument in the Montana SupremeCourt.

29. Following the decision by the Montana Supreme Court (court of last resort)affirming the verdict, H&B decided it was now reasonable to use its SIR to effectuate payment

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of the judgment and interest, instead of pursuing another option, such as filing a petition forreconsideration with the Montana Supreme Court.

30. By letter dated July 28, 2011, and other contacts bye-mail and telephone, R&Bapproached ACE seeking its agreement to pay the post-judgment interest it owed under the

~ Policy, but ACE refused. Instead, ACE sent two cheeks to H&B, one for $600,000 (the amountof the $850,000 verdict minus H&B's Liability SIR) and $4,427 (the amount of post-trial interestdue through November 17, 2009). Despite knowing that R&B believed an open disputecontinued between it and ACE for ALAE not paid by ACE, ACE included the language "finalsettlement" on the face of the $600,000 cheek;

31. H&B lined out that phrase and deposited both checks. ACE did not dishonor itscheek with the crossed-out language, andR&B used those funds, along with its own, to pay ajudgment, interest arid costs on appeal to the Patch plaintiffs in the total amount 0[$1,001,000.

32. Contemporaneously with sending the checks, ACE sent H&B a letter datedAugust 5,2011, stating tbilt it continued to stand on the position it took in November 17,2009 inthe letter from Claim Manager Zielinski, rejected the reasons stated by R&B that ACE owed thepost-judgment interest, and informed H&B that ACE owed it no further obligations.

33. The Patch plaintiffs thereafter accepted the tenderedpayment and entered asatisfaction of judgment, bringing the case between them and H&B to a final close.

COUNT IBreach of Contract

34. Plaintiff realleges and incorporates by reference all of the allegations set forth inthe above paragraphs.

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35. Under the language of the Policy, ACE had no right to unilaterally set a cap onwhat it would pay under the ALAE provisions of the contract, including an absolute refusal topay any ALAE appeal expenses like attorney fees and the continually accruing post-judgmentinterest.

36. ACE's actions converted the Policy into a non-consent poli\iY. and s t r i p p ! x ! , - , f r o " " , , " m ~ ___the Policy any value to the consent language for which H&B bad paid ACE.

37. By unilaterally reciting ALAE caps where they did not exist, and otherwisetreating the Policy as a non-consent policy, ACE denied H&B its contractual right to reasonably ,withhold its consent for ACE to use H&B's $250,000 SIR to settle a case H&B had decided toappeal, but which ACE decided fox its own reasons it preferred to settle. By taking the actions itdid, ACE breached the Policy.

38. ACE's actions also unilaterally rewrote the language of the Policy, which clearlystates that the most ALAE H&B would have to incur itself for any occurrence, before ACEwould assume its obligation to pay all further ALAE expenses related to that occurrence, was,H&B's $350,000 ALAE ,SIR. ACE conceded in its letters and by its actions, that H&B's ALAESIR had been exhausted by November 17, 2009. '

39. By its conduct ofissuing the November 17,2009 letter, and continuing to refuseto pay further ALAE thereafter, and all other conduct related thereto, ACE breaehed its contractof insurance with H&B.

40. Because of ACE's breaches of the Policy, H&B has been required to pay the feesand costs ineurred for the post-trial argument, bonding-related motions practice, a portion ofbonding costs, pre-appeal mediation, and appeal expenses in the Patch case, and also to pay post

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judgment interest to satisfy the judgment after appeal in the Patch case, along with other relatedexpenses that ACE should have paid as properly incurred ALAE expenses,

41, H&B is entitled to recover such sums, together with the fees and costs ofbringingthis case to force ACE to honor its contractual obligations under the Policy.

COUNT IIDeclaratory Judgment

42. Plaintiffrealleges and incorporates by reference all of the allegations set forth inthe above paragraphs.

43. A dispute exists between R&B and ACE as to H&B's rights under the subjectinsurance policy, and H&B is therefure entitled to bring this action for a declaratory judgmentdetermining its rights under the subject policy pursuant to the UnifolTIl Declaratory JudgmentsAct, Title 27, Chapter 8, of the Montana Code Annotated.

COUNT IIIViolations ofMont. Code Ann. Section 3318201

44.' Plaintiff realleges and incorporates by reference all of the allegations set furth inthe above paragraphs. '

45. Mont. CodeAnn. Section 33-18-201 sets forth certain unfair claim settlementpractices which are prohibited by insurers such as ACE. In particular, it is a violation of thissection, among other things, for an insurer to misrepresent insurance policy provisions relating tocoverages at issue or refuse to pay claims without conducting a reasonable investigation based onavailable information.

46. By its conduct, ACE has violated Mont. Code Ann. Section 33-18-201.

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47. Mont. Code Ann. Section 33-18-242 provides an independent cause of action toinsureds who are injured by conduct of insurers which violate Mont. Code Ann. Section 33-18201.

48. H&B is entitled to recover damages from ACE as a result of ACE's violations ofMont. Code Ann. Section 33-18-201 in the amounts to be nmven at trial

49. ACE's conduct entitles H&B to an award of punitive damages in accordance withMont. Code Ann. Sections 27-1-220 and22 1.

PRAYER FOR RELIEFWHEREFORE, H&B prays for judgment against ACE as follows:

a. For a declaration that under the Policy ACE was required to continue topay H&B's ALAE expenses, and that under the Policy ACE is obligated to pay all post-judgmentinterest and bonding costs.

b. Against ACE for breach of contract and awarding H&B al l damagessuffered by it in an amount to be determined at trial.

c. Against ACE for violations of Mont. Code Ann. Sect ion 33-18-201 andawarding H&B all damages suffered by it as a result of ACE's violations in an amount to bedetermined at trial.

d. Against ACE for punitive damages as provided by Montana law.e. For pre-judgment and post-judgment interest as allowed and required by

law.f. For all attorney's fees and costs, including the attorney fees and costs of

this lawsuit, the post-trial attorney fees and costs of the Patch lawsuit, and all other costs and feesincurred by H&B because ACE has" force[d] [H&B] to assume the burden oflegal action to

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yle Anne Grayason S. Ritchie

obtain the full benefit of the insurance contract" it has with ACE. Mountain West Farm BureauMuJ. Ins. Co. v. Brewer, 2003 MT 98, 136,315 Mont. 231, 69 PJd 652 (Mont. 2003).

g. For all such other and further relief as the Court deems just and properunder the circumstances.

JURy DEMANDPlaintit fhereby demands trial by jury of all issues properly triable by jury.

Dated this 14th day of November, 2011.

HOLLAND& HART LLP401 North 31 st Street, Suite 1500P.O. Box 639 Billings, Montana 59103-0639 . ATIORNEYS FOR PLAlNTlFF HILLERlCH &BRADSBYCO.

4716361JDOCX

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, ,, , ..... t , ' . . , .

,Kyle Anne GrayJason g. RitchieHOLLAND &. HART LLP R F - ~ ~ ~ V E D01 North 31st Suite 1500P.O. Box 639 , NOV 2 8 2011Billings, Montana 59103-0639 Telephone: (406) 252-2166 Fax; (406) 252-1669 A T T O R N E Y S F O R P L ~

MONTANA FIRST JUDICIAL DISTRICT COURT, LEWIS &. CLARK COUN1Y, MONTANAHillerich&. Bradshy Co., ) No, BDV2011-909)

Plaintiff; , ) Judge Jeffrey M. Sherlock)v. )) AMENDEDACE American Insurance Company, , ) SUMMONS) Defendant. )

THE STATE OF MONTANA SENDS GREETINGSTO THE ABOVE-NAMED DEFENDANT: ACE American ~ a n c e Co.

You are hereby summoned to answer the Complaint in this action which is filed in theoffice of he Clerk of this Court, a copy ofwhich is herewith served upon you and to file youranswer and serve a copy thereof upon ,the'plailltifi's attorney within thirty (30) days after theserviceof this Summons, exclusive of the' day of service; and in case of your failure to appear oranswer, j u d g m ~ t will betaken against you by default, for the ~ l i e f demanded in the Complaint. '

WITNESS my band and the seal of said Court this -Lf"day ofNovernber, 201 LNANCY SWEENEYCLERK OF DISTRICT COURT By. __ ~ ___________________

, Deputy.clerk, ,

EXHIBIT A



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I I" .,..... , ..... :

Jason S. RitchieKyleA. GrayHolland &Hartw401 North 31st StreetSuite 1500P.O.Box639B i l l ~ , M o n ~ S ~ 9 1 ~ O ~ 3 - ~ O ~ 6 3 ~ 9 L - ________ ____________ ___________________A T T O R N E Y S F O R P L A I N ~ F .

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hillerich & bradsby co. v. ace american insurance company complaint

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