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Valls v. Allstate Ins. Co.

Citation: 919 F.3d 739Docket: No. 17-3495-cv; August Term 2018

Court: Court of Appeals for the Second Circuit; April 2, 2019; Federal Appellate Court

Narrative Opinion Summary

The case involves Connecticut homeowners contesting the U.S. District Court for the District of Connecticut's dismissal of their complaint against Allstate Insurance Company. The homeowners alleged that their insurance policy should cover damages to their basement walls, which were affected by defective concrete, resulting in significant cracking. Their claims included breach of contract, breach of the implied covenant of good faith and fair dealing, and violations of the Connecticut Unfair Insurance Practices Act (CUIPA) and the Connecticut Unfair Trade Practices Act (CUTPA). The policy in question is an 'all-risk' policy with specific exclusions and conditions for coverage of collapses, defining a covered collapse as 'entire, sudden, and accidental.' The court affirmed the district court's decision, concluding that the gradual cracking did not meet the policy's definition of a collapse, as it lacked suddenness and did not constitute an entire collapse. The court also declined to certify the legal question to the Connecticut Supreme Court, emphasizing Allstate's right to remain in federal court. Consequently, the court found no breach of contract or bad faith by Allstate, resulting in the dismissal of the homeowners' claims under CUTPA/CUIPA.

Legal Issues Addressed

Breach of Contract and Bad Faith Claims

Application: The court concludes that Allstate did not breach the contract or act in bad faith by denying coverage, as the policy terms were correctly interpreted to exclude the Vallses' claims.

Reasoning: Consequently, Allstate did not breach its contract by denying coverage, resulting in the failure of the Vallses' bad faith and CUTPA/CUIPA claims.

Certification to State Supreme Court

Application: The court decides against certifying the coverage question to the Connecticut Supreme Court, noting the discretionary nature of certification and Allstate's strong objection.

Reasoning: The court ultimately affirms the district court's judgment, concluding that the policy terms do not provide coverage for the claimed damage. Additionally, the court considered certifying the coverage question to the Connecticut Supreme Court but decided against it, primarily due to Allstate's strong objection.

Definition of 'Collapse' in Insurance Policies

Application: The court holds that the insurance policy's requirement for a 'collapse' to be 'entire, sudden, and accidental' precludes coverage for the gradual cracking of the basement walls.

Reasoning: The gradual erosion and cracking of the Vallses' basement walls do not meet the Policy's definition of 'collapse,' which requires damage to be 'sudden and accidental.'

Exclusion of Coverage for Gradual Deterioration

Application: The court finds that the insurance policy does not cover damages from gradual deterioration, interpreting 'sudden' to imply abruptness, which is not met by the ongoing cracking of the walls.

Reasoning: The absence of a sudden event disqualifies the damage from coverage under the Policy. Even if the cracking were considered sudden, it would not amount to an 'entire collapse,' as the Policy explicitly excludes coverage for mere 'cracking.'

Insurance Policy Interpretation under Connecticut Law

Application: The court applies standard contract interpretation principles, construing ambiguous terms favorably for the insured. However, the policy in question explicitly defines 'collapse,' and thus, the court interprets this definition strictly.

Reasoning: Connecticut law applies to the interpretation of the insurance Policy in question, utilizing standard contract interpretation principles. Ambiguous terms are construed favorably for the insured, as the insurance company drafted the policy.