Eddie Briggs v. State Farm Fire & Casualty
673 F. App'x 389
| 5th Cir. | 2016Background
- In 2011 a tornado damaged the Briggses’ home; they claimed the $256,800 policy limit from State Farm, which paid $158,778.58 after its estimate that repairs cost less than the limit.
- The Briggses sued alleging improper adjustment and underpayment, including failures in pricing, use of software, contractor licensing, claim handling, and intimidation; they sought breach of contract, extra-contractual compensatory damages, and punitive damages.
- The district court bifurcated trial: Phase One tried breach of contract; Phase Two reserved extra-contractual and punitive claims that require showing State Farm lacked an "arguable basis" for its position.
- During Phase One the court excluded the Mississippi Homeowner Insurance Policyholder Bill of Rights as irrelevant to breach of contract; the jury nevertheless found for the Briggses on breach and awarded $72,521.42 (still below the policy limit when combined with payments already made).
- Before Phase Two the district court held an evidentiary hearing, readmitted Phase One evidence, and allowed proffers; it then granted State Farm's motion for judgment as a matter of law on the remaining claims, finding the evidence insufficient to show no "arguable basis."
- The Briggses moved for a new trial challenging bifurcation, exclusion of the Bill of Rights, and the JMOL; the district court denied relief and the Briggses appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused discretion in bifurcating trial | Briggs: All compensatory-related claims (including extra-contractual compensatory claims) should be tried together with breach; only punitive should be separate | State Farm: Extra-contractual and punitive claims share the distinct element (no "arguable basis") and are properly tried together in a separate phase to avoid prejudice and for economy | Court: No abuse of discretion; bifurcation was proper for convenience, avoiding prejudice, and economy |
| Admissibility of Mississippi Policyholder Bill of Rights in Phase One | Briggs: Regulations show State Farm's duty and breach in claim handling and should be admitted | State Farm: Not relevant to contract breach trial | Court: Exclusion was not an abuse; Bill of Rights not relevant to breach and Briggses failed to show substantial prejudice |
| Grant of JMOL on extra-contractual and punitive claims | Briggs: Evidence from Phase One + hearing created fact issue whether State Farm lacked an "arguable basis" for its valuation | State Farm: Its claim position was at least arguable; dispute was over amount, not denial of coverage | Court: JMOL affirmed—evidence showed a "pocketbook" dispute and reasonable minds could differ, so no showing that insurer lacked an arguable basis |
| Waiver of any separate negligence claim | Briggs (reply): Asserted a negligence claim that should have been in Phase One | State Farm: Any such claim was waived by Briggses | Court: District court properly found the negligence claim waived |
Key Cases Cited
- First Tex. Savings Ass'n v. Reliance Ins. Co., 950 F.2d 1171 (5th Cir. 1992) (bifurcation is discretionary and reviewed for abuse of discretion)
- U.S. Bank Nat'l Ass'n v. Verizon Commc'ns, Inc., 761 F.3d 409 (5th Cir. 2014) (evidentiary rulings reviewed for abuse of discretion; prejudice required to reverse)
- Broussard v. State Farm Fire & Cas. Co., 523 F.3d 618 (5th Cir. 2008) (Mississippi law requires prompt, adequate investigation and permits bad‑faith/punitive liability; standard for JMOL review)
- Universal Life Ins. Co. v. Veasley, 610 So. 2d 290 (Miss. 1992) (recognition of extra‑contractual compensatory damages where no arguable basis exists but conduct not punitive)
- Windmon v. Marshall, 926 So. 2d 867 (Miss. 2006) (plaintiff bears heavy burden to show insurer had no reasonably arguable basis)
- Tutor v. Ranger Ins. Co., 804 F.2d 1395 (5th Cir. 1986) (distinguishing ordinary disputes over valuation from conduct lacking an arguable basis)
- Essinger v. Liberty Mut. Fire Ins. Co., 534 F.3d 450 (5th Cir. 2008) (discussing availability of extra‑contractual remedies under Mississippi law)