Stahulak v. U-Haul International, Inc.
3:24-cv-00825
N.D. Ind.Jun 11, 2025Background
- Plaintiffs Carl and Linda Stahulak own a 42-foot Sea Ray boat insured by Geico Marine Insurance Company.
- In November 2021, while in storage at Trail Creek Marina, the boat was damaged by an unidentified U-Haul truck.
- The Stahulaks filed a claim with Geico for the loss, alleging improper adjustment and bad-faith conduct by Geico, including hiring an unqualified surveyor.
- Plaintiffs sued both U-Haul and Geico in Indiana state court, later amending their complaint to include intentional infliction of emotional distress (IIED) among other claims.
- Geico removed the case to federal court and moved to dismiss the IIED claim (Count V) under Rule 12(b)(6) for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of IIED Claim | Geico’s conduct was extreme, outrageous, and caused severe distress | Conduct was not extreme/outrageous or intended to harm | Dismissed; facts do not meet IIED standard |
| Incorporation of Complaint Paragraphs | Intended to incorporate all factual allegations to support IIED | Only certain paragraphs incorporated into Count V | Court considered all paragraphs as incorporated |
| Adequacy of Factual Allegations | Claimed facts stated severe emotional distress and repeated payment | Merely recited elements, lacking factual support | Allegations insufficient; did not state plausible IIED claim |
| Intent Requirement for IIED | Implied Geico’s refusal was intentional/reckless to cause harm | No showing of intent to harm emotionally | No sufficient facts showing intent or recklessness |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for stating a plausible claim under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 554 (complaint must nudge claim from conceivable to plausible)
- Serino v. Hensley, 735 F.3d 588 (elements and strict standard for IIED under Indiana law)
- Waldrip v. Waldrip, 976 N.E.2d 102 (IIED requires conduct exceeding all bounds of decency)
- Conwell v. Beatty, 667 N.E.2d 768 (IIED liability only for "atrocious, intolerable" conduct)
- Branham v. Celadon Trucking Servs., Inc., 744 N.E.2d 514 (defines outrageous conduct for IIED)