ocaa news aug 2014 20 pg - oregon casualty …oregoncasualtyadjusters.org/articles/ocaa news aug...
TRANSCRIPT
Also in this Issue
Smith Freed & Eberhard Welcomes Five New Partners pg 13
Sixteen Attorneys Honored as Super Lawyers & Rising Stars in OR & WA pg 13
Upcoming Conferences pg 19
OCAA Membership Application pg 19
Next OCAA Meeting is September 9, 2014
See page 2 for time, location & other details
August 2014 www.oregoncasualtyadjusters.org | PO Box 87 • Dexter, OR 97431
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OCAA Membership
We extend membership to anyone involved in the resolution of an insurance claim: Claims Adjusters, Casualty Claims Support Staff, Defense Attorneys, Private Investigators, Fire Origin & Cause Experts, Forensic Engineers and Forensic Accountants. Trade Vendors are asked to support the organization by be-coming a Vendor Partner-Advertiser in lieu of membership. To apply for membership or to RENEW DUES for 2014-15, please see page 19, or visit our website where you’ll find the membership application in PDF format and the opportunity to pay dues online with a credit card.
www.oregoncasualtyadjusters.org
Message from the OCAA Board By Tammi McEnaney, President
— See page 3
Case Study
“Temperi Omnia Est.” or in Other Words, “Timing is Everything”
— See page 5
DCBS Rule Changes — See page 9
OCAA — August 2014
Time 11:30am to 1:00pm Location Old Spaghetti Factory 715 SW Bancroft St, PDX
Menu Choices $15 To be determined
Checks, cash or credit card accepted
RSVP Requested www.oregoncasualtyadjusters.org
Next OCAA Meeting
Sept 9, 2014
This newsletter is a publication of the Oregon Casualty Adjusters Association It is produced and distributed monthly by
Alquemie Publishing Ink (541) 937-2611 www.alquemiepublishing.com
Mail correspondence to: PO Box 87, Dexter, Oregon 97431
Fax to: (541) 937-4286 Email to: [email protected] or [email protected]
OCAA Vital Statistics 2014-15
ANNOUNCEMENTS POSITION OPEN
BOWLING TAMMI MCENANEY, 503/736-7829
BUDGET & FINANCE COMMITTEE POSITION OPEN
CONSTITUTION & BYLAWS PAST PRES. & CHAIR SPUNKY GRAY, 800/788-3933 PAST PRES. RON GRAY EMPLOYMENT TREVOR ARNOLD, 503/505-7534
GOLF PAST PRES. MARK JOHNSON, 503/565-2833 PAST PRES. MIKE MEADOWS, 503/736-7802
MEMBERSHIP PAST PRES. PATTY FERGUSON, 800/242-2923 X2551 NEWSLETTER, SYMPOSIUM & WEBSITE COORDINATOR BARB TYLER, ALQUEMIE PUBLISHING 541/937-2611, [email protected] PARLIMENTARIAN PAST PRES. RON GRAY, 855/426-8898
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- 2 -
PRESIDENT TAMMI MCENANEY LIBERTY MUTUAL 503/736-7829 [email protected]
PRESIDENT-ELECT TREVOR ARNOLD MCLARENS 503/505-7534 [email protected]
SECRETARY KAYLA BEWERSDORFF LIBERTY MUTUAL 503/736-7828 [email protected]
TREASURER SEAN MCGUIRE LIBERTY MUTUAL 503/736-7824 [email protected]
PROGRAM CHAIR POSITION OPEN
MEMBER-AT-LARGE POSITION OPEN
IMMEDIATE PAST PRESIDENT ERICA MCDANIEL LIBERTY MUTUAL 503/736-7185 [email protected]
Standing Committees
Who will take home the pot?
YOU MUST BE PRESENT TO WIN!
At each monthly meeting someone could be
the lucky winner! Will you be present to
win at the September meeting?
Up for grabs in Sept: $50
It pays to attend a meeting!
Crying Corner
Don’t get your name listed here… attend a meeting to win!
Featured Topic: “Structural Repairs & Current Building Code”
with Travis Sanders of CASE Forensics
Note: No August meeting! Next meeting will be September 9.
~ Dues for the year 2014-15 are due starting NOW! ~
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OCAA — August 2014 - 3 -
To submit an article to this publication contact Barb Tyler at [email protected] or 541/937-2611. Length of the article is not as important as its content, which should be educational and directed
toward the property/casualty adjuster.
Membership in OCAA ~ Time to Renew Dues!
We extend membership to anyone involved in the resolution of an insurance claim: Claims Adjusters, Casualty Claims Support Staff, Defense Attorneys, Private Investigators, Fire Origin & Cause Experts, Forensic Engineers and Forensic Accountants. Trade Vendors are asked to support the organization by becoming a Vendor Partner-Advertiser in lieu of membership.
To apply for membership or to RENEW DUES for 2014-15, please visit our website where you’ll find the membership application in PDF format and the opportunity to pay dues online with a credit card.
www.oregoncasualtyadjusters.org
OCAA Board Message by Tammi McEnaney, Liberty Mutual
~ Welcome New Vendor Partner ~
Magnificent Mention! Thank you to past presidents Mark John-son and Mike Meadows both from Ore-gon Mutual, for coordinating our annual Golf Tournament.
Welcome to a new and exciting upcoming year! First, I would like to take this opportunity to announce that I have made the decision to stay on the board as the new President. I am ex-cited and a bit anxious at the same time. Some of you that know me know that I can be a quiet and shy person at times. Once I get to know you, I can be very open. I have gotten the opportunity to know many of the members and vendors over the years and I look forward to getting to know more of them and look forward to leading the organization.
I am excited to introduce the newest member of the board, Kayla Bewersdorff. She works at Liberty Mutual Insurance and has joined as the Secretary and comes in with several years of Insurance experience. I believe she will be a great asset to the organization. Please join in welcoming her to her new role. I would also like to welcome back Trevor Arnold as President-Elect, and Sean McGuire who will remain as Treasurer. We are currently looking for a volunteer to fill the Program Chair position. This individual is responsible for securing our meeting speakers and presentation topics. If you ever wanted a voice in the topics to be presented at our meet-ings, this is the position for you. We also still have a vacancy for a Member-at-Large. Please contact any board member if you or someone you know is interested.
The board has been meeting to discuss some new and exciting proposed changes for this upcoming year. More information to come later! We are always open to discuss any ideas, com-ments, or concerns, so please bring them to any one of the board members.
Please remember that it is time to renew your dues in our great organization. The OCAA year runs from August 1, 2014 to July 31, 2015. Dues right now are discounted at $25 for the year; they go up to $30 on November 1. So please renew now to take advantage of the $5 savings! The membership applica-tion, which should accompany your payment, can be found toward the back of this issue, or online where you can pay with a credit card. [Note: If you paid dues in the month of July in order to golf, that payment will be applied toward this new dues year.]
Thank you all for your participation in the past year(s) and I look forward to seeing what this new year has in store!
~ Welcome New Vendor Partner ~
OCAA — August 2014
From the desk of Jeff Eberhard: When looking at the duty to defend or indemnify, timing is key. Always look to the under-lying action that is possibly giving rise to those two duties because Oregon courts and judges care very much about what is going on and will make their decisions based on the facts of the underlying case.
Claims Pointer: When a claim is tendered to an insurance carrier, there rises the two-pronged issues of the duty to de-fend, and the duty to indemnify. The duty to defend is often addressed before the duty to indemnify because it can be de-termined by examining the complaint alone. This is because the insurer has a duty to defend if the complaint demonstrates any basis at all for which the insurer provides coverage. The duty to indemnify only arises if the facts at trial establish the liability of the insured, whereupon the insurer’s duty to in-demnify arises as long as the insured’s conduct is covered by the policy. Regardless, if these duties are implicated based on an underlying lawsuit currently being prosecuted, Oregon courts will hold that the underlying lawsuit must be pursued sufficiently via completed discovery or trial initiation prior to either duty becoming prevalent and implicated in a coverage action.
Scottsdale Insurance Company v. Ortiz & Associates, Inc, 2014 WL 1883653, May 9, 2014 (Unpublished)
Several years ago, a highway project was initiated in and around Kennewick, Washington. During the course of that construction project, a fatal tragedy occurred and Brian Lacy was allegedly struck and killed by a dump truck. In August of 2012, Lacy’s significant other brought a wrongful death action against Inland Asphalt Company (“Inland”). Inland was the general contractor for the construction project with the State of Washington. Ortiz & Associates, Inc., (“Ortiz”) was a sub-contractor for Inland on the project, and had listed Inland as an additional insured on its own policy. Scottsdale was the excess insurance carrier for Ortiz, authorizing coverage for anything above and beyond what the additional insured policy would cover.
Though subcontractor Ortiz originally complied with the duty to defend provision in their policy with Inland, their insurance later recanted and refused to continue in that role (for un-
(See Case Study… continued on page 7)
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Case Study
“Temperi Omnia Est.” or in Other Words, “Timing is Everything” Case Study by Jeff Eberhard
OCAA — August 2014
known reasons not addressed by the Court). As such, at some point Inland advised Scottsdale that depending on the outcome of the underlying wrongful death case, the Scottsdale policy could be triggered. Inland never formally tendered to Scotts-dale, they merely put them on notice as it were. Scottsdale then instituted a declaratory action against Inland, claiming that there was an exclusion in the excess policy that precluded any duty to defend or indemnify Inland in the underlying ac-tion. Inland moved to stay Scottsdale’s action pending the results of the underlying wrongful death action, thereby lead-ing to the opinion we discuss now.
Scottsdale contended that when Inland told them that the un-derlying wrongful death action might implicate the excess coverage policy, that Inland had in fact tendered defense of that underlying action to them. With this in mind, we must first preliminarily address the duties to defend and indemnify. All other things being equal, it is well known in Oregon courts that the duty to defend is often addressed before the duty to indemnify, because it can be determined by examining the complaint alone. The insurer has a duty to defend if the com-plaint provides any basis for which the insurer provides cover-age. The duty to indemnify on the other hand arises when facts proven at trial establish the liability of the insured, and the conduct of the insured is covered by the pertinent policy. Thus, in order to determine the existence of a duty to indem-nify, in a case like this where the duty is implicated by an un-
Case Study… (Continued from page 5) derlying lawsuit, a court must examine the facts of that under-lying lawsuit.
The crux of the conflict between Scottsdale and Inland is an interesting one. Inland first argues that it did not actually ten-der defense of the underlying action to Scottsdale, it merely put them on notice. Inland contended that there was certainly no duty to indemnify because the underlying action was still ongoing. More interesting, Inland argued that proceeding with the declaratory action would ironically force Inland to admit liability in the underlying action in order to defend itself in the declaratory action. Scottsdale countered by arguing that the court could decide the duty to indemnify because if there was a judgment in the underlying action, it would almost certainly exceed the base coverage and reach into the Scottsdale excess coverage. Further, Scottsdale contended that the excess policy clearly had an exclusion for the type of accident that led to the underlying lawsuit, and that failing to decide upon the current declaratory action would force Scottsdale to fund a settlement of an uncovered claim, and/or force it to defend itself against future claims for failing to fund a settlement.
The court considered the two sides carefully, and used two primary Oregon law doctrines to make their decision. First, to the benefit of Inland, “Oregon courts recognize that when the underlying tort action is still underway, it is appropriate to stay a simultaneous coverage action determining the duty to indemnify if the coverage action places the insured in the con-flictive position of being required to abandon its denial of
(See Case Study… continued on page 9)
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OCAA — August 2014
liability in the underlying case in order to demonstrate cover-age.” Thus, it is appropriate to wait until the underlying ac-tion is resolved and liability established before determining the duty to indemnify. Second, federal courts have discretion as to whether declaratory relief may be exercised (this related to a side issue of subject matter jurisdiction that was not dis-cussed in length by the court).
Holding primarily to the first doctrine, the court simply went with the “keeping it simple” concept. Discovery was not yet complete in the underlying case. Trial was not even to take place until January of 2015. Regardless of whether Scotts-dale felt their excess coverage had an exclusion for the type of accident that led to the underlying lawsuit, the court sim-ply felt it was too early to sign off on the declaratory action when all the facts of the underlying case had yet to even be compiled. As such, the court determined the following: “[U]ntil the issue of liability is resolved in the underlying lawsuit, this Court will not entertain the declaratory judgment deter-mination that Scottsdale seeks. Doing so would place Inland in a conflictive position that could undermine its position in the underlying lawsuit and would require fact finding identi-cal to that which will occur in the underlying lawsuit in Washington State court.”
So, once again, as with all things in life, … “Temperi Omnia Est.”
(NOTE: This opinion has not been published as of yet, given its very new status. It is provided to demonstrate how the court approaches the issues involved in the case.)
— View the full case opinion at: http://law.justia.com/cases/federal/district-courts/oregon/ordce/3:2013cv01791/114132/39
— If you would like to be notified of these new cases, please send an email to: [email protected].
This article is to inform our clients and others about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information without seeking professional counsel.
Case Study… (Continued from page 7)
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Find this and other Case Study articles on our website at: www.oregoncasualtyadjusters.org
Heather Becker Cell: (503) 575-6161
14200 SE McLoughlin Blvd Suite #G Milwaukie, OR 97267 Office: (503) 594-0545
Toll Free: (866) 993-3817 Fax: (503) 594-0262
DCBS Rule Changes
Rule Caption: Actions by Director for Restitution or Other Equitable Relief
Rule ID 10-2014
The Oregon Insurance Division recently filed the above per-manent rule.
This rule clarifies when and how the director may exercise the discretionary authority to seek restitution or other equita-ble relief on behalf of a consumer who has suffered damages as a result of an insurer's violation of the Insurance Code, applicable federal law or the insurer's breach of an insurance contract or policy that the insurer has with the consumer. The rule defines "consumer," "actual damages" and "equitable relief" and specifies when the director will seek relief. The rule specifically states that the director will not seek relief on behalf of a consumer who is entitled to an exclusive remedy under the workers compensation laws of this state and speci-fies that the director may reduce actual damages upon a showing that the consumer has failed to reasonably mitigate damages.
This permanent rule will apply on and after the date the rules are adopted. The department adopted temporary rules effec-tive December 27, 2013 and this permanent rule replaces the temporary rules.
(See Rule Changes… continued on page 13)
OCAA — August 2014
Smith Freed & Eberhard Welcomes Five New Partners — Portland, Oregon (June 27, 2014) – Smith Freed & Eberhard is pleased to announce that four of its current trial lawyers have become recognized as partners in the firm. The attorneys that are honored with this designation are: Stephen Rasmussen, Joseph Rohner IV, Jeremy Reeves, and Catherine Becker. In addition, experienced litigator Tho-mas McCurdy has joined the firm as a partner, he will be based out of the firm’s Seattle office.
Stephen Rasmussen has over 25 years of litigation experi-ence. He specializes in defending physicians and other health-care professionals in complex medical malpractice claims. Steve’s long-lasting client relationships allow him to develop effective litigation prevention strategies that address potential weaknesses before they result in legal action.
Joseph Rohner IV has a broad litigation based practice. He has provided defense in numerous fields including securities law, personal injury, premises liability, product defects, and construction defect cases.
Jeremy Reeves works primarily on personal injury and com-mercial liability claims. He also has experience working on complex liquor liability cases involving premises liability claims and allegations of over-service and inadequate security.
Catherine Becker enjoys helping her clients through the stresses and pains of litigation. Whether handling an automo-tive defense claim, or a complicated commercial liability case, Catie is sensitive to her clients’ needs and provides a tailored litigation approach.
Thomas McCurdy is a knowledgeable trial lawyer with years of experience handling civil litigation matters. From product liability and personal injury matters, to healthcare providers facing medical malpractice suits, Tom provides his clients with efficient and cost-effective legal solutions.
Sixteen Attorneys Honored as Super Lawyers & Rising Stars in OR & WA Portland, Oregon (August 6, 2014) – Sixteen of Smith Freed & Eberhard’s forty attorneys have been honored by their peers and clients as 2014 Oregon and Washington Super Lawyers or Rising Stars. This acknowledgement of such professional achievement by forty percent of the firm’s trial lawyers is a feat that distinguishes the firm from others in the insurance defense market. The icing on the cake? Denny Freed, a founding partner of the regional defense firm, was honored (for the second year in a row) as a Top 50 Super Lawyer in Oregon.
(See Awards… continued on page 19)
Find your legislative representative or track a bill at http://gov.oregonlive.com
Contact Us Today: Jenna Gibbs [email protected] 720.560.6640 www.PTCforensics.com
For further details, and electronic versions of the filing docu-ments associated with this permanent rule, we invite you to visit our website at: http://www.oregon.gov/DCBS/insurance/legal/laws/Pages/recentrules.aspx.
Rule Caption: Equality in Treatment of Same-Sex Mar-riages Validly Performed
Rule ID 11-2014
The Oregon Insurance Division recently filed the above per-manent rule.
This rule requires entities regulated by the Department of Consumer and Business Services to treat same-sex marriages validly performed the same as any marriage of heterosexual couples validly performed. The rule is necessary to comply with the recent federal court decisions by the United States Supreme Court and Oregon District Court that held prohibi-tions on same gender marriages unconstitutional under the U.S. Constitution.
This permanent rule will apply on and after the date the rules are adopted.
For further details, and electronic versions of the filing docu-ments associated with this permanent rule, we invite you to visit our website at: http://www.oregon.gov/DCBS/insurance/legal/laws/Pages/recentrules.aspx.
Rule Changes… (Continued from page 9)
- 13 -
www.oregoncasualtyadjusters.org If you are an employer seeking Claim Professionals and
would like to post a job opening on our website at no charge, please contact OCAA President-Elect, Trevor Arnold at
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OCAA — August 2014 - 19 -
Send your completed application, along with your check payable to: OCAA — PO Box 87, Dexter, OR 97431
Application is: (Check one) Renewal ______ New ______ Change ______ Referred by ______________________
Applicant is: (Check one) Active Member Associate Member — Any person employed by an insurance company or self-insured
Active Casualty Claims Adjuster entity engaged as ACTIVE SUPPORT STAFF in the adjusting of (Liability/Property/WC) or Supervisor Casualty Claims; also includes Attorneys, Private Investigators, Fire Origin & Cause Experts, Forensic Engineers, Forensic Accountants, whose work involves insurance defense work Honorary Member — OCAA Past President Retired Retired — Any Claims Adjuster or Supervisor retiring while an Active Member
If you do not qualify for membership in the OCAA, please visit the OCAA website at www.oregoncasualtyadjusters.org, click on the Resource page then click on "Advertise with Us" for information on how to become a Vendor Partner. Name__________________________________________ Job Title_______________________________________ Company______________________________________ Property Casualty Auto Work Comp Other
Address____________________________________ City____________________ State_____ Zip________________ Work Telephone __________________x______ Email_________________________________________________
At what address would you prefer to receive your OCAA newsletter? Home Work Email (circle one)
OCAA ANNUAL MEMBERSHIP APPLICATION FOR 2014-15 AUGUST 1, 2014 TO JULY 31, 2015
NEW MEMBERSHIP AND RENEWALS $25.00 (RENEW NOW! DUES GO UP TO $30 ON NOVEMBER 1, 2014) (Membership includes monthly issues of the OCAA newsletter!)
OREGON CASUALTY ADJUSTERS association
Attorneys selected to the 2014 Oregon Super Lawyers list are: Jeffrey Eberhard - Civil Litigation Defense Robert “Bob” Smith - Insurance Coverage Dennis “Denny” Freed - Personal Injury Defense: General (Top 50 Oregon Super Lawyer List) Jeffrey Hansen – Personal Injury Defense: General Bruce Gilbert – Construction Litigation John Kreutzer – Employment Litigation Defense Katie Buxman – Personal Injury Defense: General
Attorneys selected to the 2014 Oregon Rising Stars list are: Joshua Hayward – Civil Litigation Defense Anne Cohen – Construction Litigation Ryan McLellan – Personal Injury Defense: General Lance Brooks – Civil Litigation Defense Cliff Wilson – Civil Litigation Defense Joseph Rohner, IV – Business Litigation Stephan Lopez – Personal Injury Defense: General Jakob Lutkavage-Dvorscak – Construction Litigation
Attorney selected to the 2014 Washington Rising Stars list:
Thomas McCurdy – General Litigation
For additional information you can view the 2014 Super Law-yers Magazine (Oregon and Washington editions) or visit www.superlawyers.com.
Awards… (Continued from page 13) 2014 Financial Crimes & Digital Evidence Conference
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For more information and to register go to: www.financialcrimesconference.com
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Full day of training (5 CEU hours) on the latest trends and technology for detecting
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