Eric Chase v. Nationwide Mutual Fire Insurance Company
160 A.3d 970
| R.I. | 2017Background
- On June 25, 2010, Eric Chase’s property suffered extensive casualty damage covered by a Nationwide homeowner’s policy.
- Nationwide accepted coverage, authorized repairs, and issued a partial payment but declined further funds requested by Chase. Chase alleged dilatory conduct by Nationwide.
- Chase requested appraisal in March 2014; Nationwide rejected the appraisal demand, citing delay and missing documentation.
- Chase sued in November 2014 (breach of contract; bad-faith count later severed), more than four years after the loss.
- Nationwide moved for judgment on the pleadings under Rule 12(c), asserting Chase failed to comply with the policy’s requirement to sue within two years of loss and therefore the claim was barred.
- The Superior Court granted judgment on the pleadings; the Rhode Island Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether judgment on the pleadings was appropriate where plaintiff filed suit more than two years after loss | Chase argued the complaint’s allegations could, if true, entitle him to relief and thus survive Rule 12(c) | Nationwide argued the policy requires suit within two years of loss and Chase failed to comply | Court held judgment on the pleadings was proper; pleadings and policy show suit was untimely |
| When the contractual two-year limitation begins to run | Chase argued limitations run from insurer’s breach or formal rejection of the claim, not date of loss | Nationwide relied on clear policy language: action must be started within two years after date of loss or damage | Court held the contract unambiguously starts the two-year period from date of loss, not from rejection/breach |
| Whether estoppel barred enforcement of the two-year contractual limitation | Chase alleged dilatory conduct by insurer and argued estoppel should prevent Nationwide from invoking the contractual limitation | Nationwide contended mere negotiations/delay do not establish estoppel and no factual allegations supported inducement to delay filing | Court held Chase’s pleadings lacked sufficient factual detail to state a prima facie estoppel claim; mere conclusory allegation of dilatory conduct was inadequate |
| Whether plaintiff’s untimely submission of evidentiary exhibits below required conversion to summary judgment | Chase filed a late memorandum with exhibits attempting to support estoppel | Nationwide opposed; trial justice declined to consider untimely, unaffidavited exhibits and did not convert the motion | Court noted plaintiff did not object and affirmed the lower court’s decision not to convert to summary judgment |
Key Cases Cited
- National Refrigeration, Inc. v. Travelers Indemnity Co. of America, 947 A.2d 906 (upholding contractual two-year limitations provision)
- Hay v. Pawtucket Mutual Insurance Co., 824 A.2d 458 (recognizing validity of short contractual limitations in insurance policies)
- McAdam v. Grzelczyk, 911 A.2d 255 (describing estoppel where insurer’s conduct induced late filing)
- Greater Providence Trust Co. v. Nationwide Mutual Fire Insurance Co., 355 A.2d 718 (settlement negotiations alone do not justify estoppel)
- Haley v. Town of Lincoln, 611 A.2d 845 (pleading standards for surviving a Rule 12 motion)