Hodjat v. State Farm Mutual Automobile Insurance
211 Cal. App. 4th 1
| Cal. Ct. App. | 2012Background
- Hodjat owns Luxury Auto Sports in Santa Fe Springs and bought a damaged 2006 BMW M5 in Oct 2007, insured by State Farm.
- Policy required cooperation in claims and voided coverage for false statements or concealment of material facts.
- Hodjat reported the BMW stolen on Mar 31, 2009; State Farm investigated and collected multiple statements from Hodjat.
- State Farm found inconsistencies and potential misrepresentations, including fluctuating purchase price, repair histories, and title details with alterations, plus prior related fraud concerns involving related parties.
- State Farm denied the claim on Feb 22, 2010; Hodjat filed suit on May 3, 2010 alleging breach of contract and bad faith; summary judgment was granted for State Farm on Apr 22, 2011, and affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether misrepresentations and lack of cooperation justify denial | Hodjat contends issues in fact preclude summary judgment | State Farm properly denied under policy for false statements and noncooperation | Yes; denial justified under policy terms |
| Whether there were triable issues on bad-faith/breach claim | Disputes about investigation fairness and counsel advice create triable issues | No triable issues; denial made in good faith and based on genuine dispute | No triable issues; summary judgment affirmed on breach and implied covenant claims |
Key Cases Cited
- Collins v. Hertz Corp., 144 Cal.App.4th 64 (Cal. Ct. App. 2006) (separating objections and statements for summary judgment)
- Parkview Villas Assn., Inc. v. State Farm Fire & Casualty Co., 133 Cal.App.4th 1197 (Cal. Ct. App. 2005) (proper formatting of objections in summary judgment)
- Kim v. Sumitomo Bank, 17 Cal.App.4th 974 (Cal. Ct. App. 1994) (appellant must connect arguments to record evidence)
- Chateau Chamberay Homeowners Assn. v. Associated International Ins. Co., 90 Cal.App.4th 335 (Cal. Ct. App. 2001) (bad-faith standard for insurance denial in dispute)
- Eddins v. Redstone, 134 Cal.App.4th 290 (Cal. Ct. App. 2005) (court need not resurrect unsupported factual disputes)
- United Community Church v. Garcin, 231 Cal.App.3d 327 (Cal. Ct. App. 1991) (triable fact standard and evidence citation requirements)
- Wilson v. 21st Century Ins. Co., 42 Cal.4th 713 (Cal. 2007) (de novo review of summary judgment and evidentiary standards)
- Yanowitz v. L’Oreal USA, Inc., 36 Cal.4th 1028 (Cal. 2005) (liberal construction in opposition to summary judgment)