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Sirois v. USAA Cas. Ins. Co.

Citation: 342 F. Supp. 3d 235Docket: No. 3:16-cv-1172 (MPS)

Court: District Court, D. Connecticut; September 18, 2018; Federal District Court

Narrative Opinion Summary

In a dispute over homeowner's insurance coverage, the plaintiffs, property owners, filed suit against USAA Casualty Insurance Company for breach of contract and violations of the Connecticut Unfair Insurance Practices Act (CUIPA) and the Connecticut Unfair Trade Practices Act (CUTPA). The conflict arose from USAA's denial of coverage for damage to the plaintiffs' basement walls due to concrete cracking and deterioration, which the plaintiffs argued constituted a 'collapse' under their insurance policies. The case was moved to federal court, where USAA sought summary judgment, arguing that the policy did not cover such damages and that there was no breach of contract or violation of CUIPA/CUTPA. The court partially granted USAA's motion, dismissing the CUTPA claim but allowing the breach of contract claim to proceed, highlighting ambiguities in the policy's definition of 'collapse.' The court found a genuine dispute of material fact regarding whether the damage qualified as a 'collapse,' particularly given the plaintiffs' expert testimony about the structural deterioration. The plaintiffs' failure to establish that USAA's liability was reasonably clear led to the dismissal of the CUTPA claim. The court's decision underscores the complexities of interpreting insurance policy language and the stringent requirements for proving unfair practices under CUIPA/CUTPA.

Legal Issues Addressed

Burden of Proof in Summary Judgment

Application: The moving party must demonstrate the absence of genuine issues of material fact, while the opposing party must show specific evidence of a dispute. The court found a genuine dispute regarding the claim of a collapse.

Reasoning: Summary judgment is warranted only when the moving party proves that no genuine issue exists regarding any material fact and is entitled to judgment as a matter of law.

Connecticut Unfair Trade Practices Act (CUTPA) and Unfair Insurance Practices

Application: The court dismissed the CUTPA claim, finding the plaintiffs failed to establish USAA's liability as reasonably clear, a requirement to prove unfair settlement practices under CUIPA.

Reasoning: The plaintiffs’ reference to other lawsuits did not demonstrate that USAA’s liability was reasonably clear, and they did not contest this point but claimed the relevant case law was wrongly decided.

Definition of 'Collapse' in Insurance Policies

Application: The court evaluates the policy's definition of 'collapse' and finds the term 'caving in' ambiguous, allowing for the plaintiffs' interpretation that their basement wall conditions may qualify as a collapse.

Reasoning: The court finds the plaintiffs' interpretation of 'caving in' reasonable, noting that using a dictionary for definitions in insurance policy interpretation is appropriate. The term 'caving in' is ambiguous, as both parties present valid interpretations.

Insurance Policy Interpretation

Application: The court must interpret insurance policy terms according to their ordinary meaning, resolving ambiguities in favor of the insured, as the policies are drafted by the insurer.

Reasoning: Clear and unambiguous policy terms must be interpreted according to their ordinary meaning, and ambiguities are resolved in favor of the insured due to the insurer's drafting.