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Gingles v. Dardenne

Supreme Court of Louisiana
Mar 13, 2009
4 So. 3d 799 (La. 2009)

Summary

In Gingles, the Court considered the validity of the applicable UM form at that time, prescribed by the insurance commissioner pursuant to Bulletin 98-01.

Summary of this case from Elwakil v. Burlington Ins. Co.

Opinion

No. 2008-C-2995.

March 13, 2009.

Appeal from the Ninth Judicial District Court, Parish of Rapides, No. 223,833-G, Harry Fred Randow, J.


The instant litigation arises from an automobile accident involving a vehicle operated by the plaintiff, Carla Ann Gingles, and owned by her employer, Novartis Corporation ("Novartis"). As a result of the accident, the plaintiff filed a claim with Novartis's uninsured/underinsured ("UM") insurer, Ace American Insurance Company ("Ace American"), which denied its policy was triggered on the basis that its insured had rejected UM coverage. Subsequently, the plaintiff filed a motion for summary judgment alleging the UM rejection signed by Novartis lacked the insurance company's name and, as such, was not "properly completed" as required by La.R.S. 22:608(1)(a)(ii). While the pertinent UM rejection form did not expressly provide for the insurer's name, the applicable accompanying insurance bulletin promulgated by the Louisiana Insurance Commissioner provided that "[f]or identification purposes, the company name must be placed at the lower left-hand corner . . ." La. Bulletin LIRC 98-01. In response, Ace American filed a cross-motion for summary judgment claiming Novartis had validly waived UM coverage by complying with all of the explicit guidelines set forth in Duncan v. U.S.A.A., 06-363, p. 12 (La. 11/29/06), 950 So.2d 544, 546-547 for a complete rejection of UM coverage. Particularly, Ace American emphasized the Duncan guidelines do not mandate the provision of the insurance carrier's name on the form. After a hearing, the trial court granted summary judgment in favor of Ace American. The plaintiff applied for supervisory review of this ruling. The court of appeal reversed, finding the UM waiver invalid. Ace American's writ application to this court followed.

The sole issue presented for our consideration is whether Novartis validly rejected UM coverage. In Duncan, supra, we enumerated six requirements for a compliant UM rejection form:

Before we determine whether the statute requires that all aspects of the form be complied with, let us now consider what the prescribed form entails. Essentially, the prescribed form involves six tasks: (1) initialing the selection or rejection of coverage chosen; (2) if limits lower than the policy limits are chosen (available in options 2 and 4), then filling in the amount of coverage selected for each person and each accident; (3) printing the name of the named insured or legal representative; (4) signing the name of the named insured or legal representative; (5) filling in the policy number; and (6) filling in the date.
Id., p. 12, 950 So.2d at 546-547.

It is undisputed that the pertinent designated spaces on the form were filled out. Additionally, the form at issue in these proceedings satisfies all of the requirements of our opinion in Duncan. Under these circumstances, we find Ace American has established it is entitled to judgment as a matter of law. The court of appeal erred in holding otherwise. Accordingly, the writ is granted. The judgment of the court of appeal is reversed, and summary judgment is rendered in favor of Ace American.

JOHNSON and KNOLL, JJ, dissent and would deny the writ.

WEIMER, J., would grant and docket.


Summaries of

Gingles v. Dardenne

Supreme Court of Louisiana
Mar 13, 2009
4 So. 3d 799 (La. 2009)

In Gingles, the Court considered the validity of the applicable UM form at that time, prescribed by the insurance commissioner pursuant to Bulletin 98-01.

Summary of this case from Elwakil v. Burlington Ins. Co.

In Gingles, the Louisiana Supreme Court considered a nearly identical issue as the one presented in this writ application —whether the failure to include the company name or logo rendered the UM waiver form invalid as a matter of law.

Summary of this case from Elwakil v. Burlington Ins. Co.

In Gingles v. Dardenne, 08-2995 (La. 3/13/09), 4 So.3d 799, the supreme court reversed this court and held that the insurer's name is not required on a UM waiver form.

Summary of this case from Reid v. Fall

In Gingles v. Dardenne, 08-2995 (La. 3/13/09), 4 So.3d 799 (per curiam), the supreme court held that a UM waiver by the insured was valid despite the fact that it did not include the insurance company's name.

Summary of this case from Barras v. Cardinal Servs.

In Gingles v. Dardenne, 08–2995 (La. 3/13/09), 4 So.3d 799, the supreme court found in favor of the insurer, despite its failure to complete the UM rejection form with the name of the company in the lower left hand corner as required by Bulletin LIRC 98–01 then in effect.

Summary of this case from Hayes v. De Barton

In Gingles v. Dardenne, 08-2995 (La. 3/13/09), 4 So.3d 799 (per curiam), and in Lynch v. Kennard, 09-282 (La. 5/15/09), 12 So.3d 944 n.4 (per curiam), the supreme court rendered summary judgments in favor of insurers, because the UM selection forms at issue complied with the Duncan requirements, even though they did not comply with the Commissioner's LIRC Bulletin 98-01, requiring the insurer's name on the UM selection form.

Summary of this case from Clark v. Savoy
Case details for

Gingles v. Dardenne

Case Details

Full title:Carla GINGLES v. Kinnery DARDENNE, et al

Court:Supreme Court of Louisiana

Date published: Mar 13, 2009

Citations

4 So. 3d 799 (La. 2009)

Citing Cases

Hayes v. De Barton

First, prior Bulletin 98–01 required the company name be placed at the lower left-hand corner but provided no…

Berkley Assurance Co. v. Willis

Defendants appealed. Reversing, the court of appeal distinguished the requirements for a valid waiver of UM…