Knoxville Federal Court Dismisses Time Barred Car Accident Case: Hudson v. State Farm Mutual Automobile Insurance Co.

In Hudson v. State Farm Mutual Automobile Insurance Co., a woman was rear-ended by an unidentified driver in October 2010. Following the car accident, the woman reported the collision to her automobile insurance company. She also made arrangements to have her vehicle inspected for damage. About seven months later, the woman sought payment for medical expenses that were apparently related to the car wreck as part of her uninsured or underinsured motorist coverage.

About three months later, the insurer sent the woman a letter stating the statute of limitations would expire on the one-year anniversary of her traffic accident if she failed to settle her claim or file a lawsuit against the company prior to that date. A statute of limitations is a maximum time limit during which a lawsuit may be filed. If a plaintiff does not file his or her case before the prescribed statute of limitations expires, the plaintiff is normally permanently barred from recovering any damages, regardless of his or her harm. Soon after receiving the letter, the woman finally sought medical treatment for the injuries she allegedly sustained in the rear-end automobile crash. After an initial consultation, the woman’s doctor diagnosed her with a “lumbar torsion” that may have been caused by the motor vehicle collision, and she began receiving physical therapy. Her auto insurer then denied the woman’s personal injury claim because it determined that her physical harm was not related to the traffic crash.

A few days before the statute of limitations expired, the injured woman filed a case against her insurer in Blount County, Tennessee. Several months later, she filed a second case, adding her husband as a loss of consortium plaintiff and the unknown driver as a defendant. She later amended her lawsuit to include a claim for negligence against the unknown motorist who struck her vehicle as well as Tennessee Consumer Protection Act (“TCPA”), bad faith, and breach of contract claims against her car insurance company. The insurer then successfully removed the lawsuit from state court to the Eastern District of Tennessee, Knoxville Division.

Following removal, the insurance company filed a motion for summary judgment. In order to prevail on such a motion, a party to a lawsuit must demonstrate that no issue of material fact is in dispute and that the party is entitled to judgment as a matter of law. In addition, a court is generally required to construe the facts of the case in favor of the non-moving party. Still, the mere possibility that a factual dispute may exist is not enough to defeat a motion for summary judgment.

According to the Eastern District of Tennessee, the woman’s second complaint was barred by the statute of limitations because it was filed more than one year after the date of her alleged harm. Similarly, the federal court granted summary judgment in favor of the insurer over her husband’s loss of consortium claim. The court also granted the insurance company’s motion with regard to the woman’s bad faith insurance claim because she failed to plead the elements required to show the insurer acted in bad faith when handling her damages claim. In addition, the federal court dismissed the woman’s equitable estoppel argument against the automobile insurance company. Equitable estoppel is a legal doctrine that allows a court to deny a party that somehow acted unfairly any requested relief that the party may otherwise be entitled to.

Next, the court dismissed the woman’s TCPA claim because she failed to demonstrate an ascertainable loss sufficient to support it. Finally, although the woman’s breach of contract claim over her uninsured or underinsured motorist coverage was time barred, the court stated her property damage claim remained unresolved because the insurer failed to address it in the company’s motion for summary judgment.

If you were injured in a motor vehicle collision, you need a knowledgeable lawyer on your side to help you protect your rights. The hardworking attorneys at the Hartsoe Law Firm, P.C. provide quality legal representation to injured clients in Knoxville and throughout Eastern Tennessee. To speak with a seasoned lawyer about your personal injury case, you should call the Hartsoe Law Firm, P.C. today at (865) 804-1011. You may also contact us through our website.

Additional Resources: Hudson v. State Farm Mutual Automobile Insurance Co., Dist. Court, ED Tennessee 2013

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