SDNY Predicts California Would Adopt Bad Faith Exception to Notice-Prejudice Rule

by Cozen O'Connor


The U.S. District Court in the Southern District of New York recently granted, in part, a reinsurer’s motion for summary judgment on a late notice defense, but ruled the issue of whether a reinsurer was prejudiced by the cedent’s late notice will have to be determined at trial. In Ins. Co. of the State of Pa. v. Argonaut Ins. Co., Civ. No. 12-6494, 2013 U.S. Dist. LEXIS 110597 (S.D.N.Y. Aug. 6, 2013), the Insurance Company of the State of Pennsylvania (ICSOP), filed suit against its quota-share reinsurer, Argonaut, seeking reimbursement under a facultative reinsurance certificate (the certificate). ICSOP sought to recover losses paid to its insured for asbestos bodily injury claims pursuant to a reinsured excess umbrella policy.

On cross-motions for summary judgment, the court granted, in part, Argonaut’s motion, finding that ICSOP breached its notice obligation under the certificate. However, because discovery to date had been limited to the issue of late notice, “whether Argonaut can demonstrate that it suffered actual and substantial prejudice from the breach, and whether ICSOP’s gross negligence or bad faith excuses Argonaut from demonstrating prejudice” will be determined at trial. Id. at 2. The ruling in ICSOP is significant for several reasons, but the court’s prediction that the California Supreme Court would adopt the “bad faith” exception to the notice-prejudice rule, as applied to reinsurance disputes, is most noteworthy. The so-called bad faith exception was first articulated by the U.S. Court of Appeals for 2nd Circuit in Unigard Sec. Ins. Co. v. North River Ins. Co., 4 F.3d 1049 (2d Cir. 1993), under New York law, and has subsequently been applied by state and federal courts in multiple jurisdictions. Under that exception, a reinsurer need not prove prejudice if it can show deliberate deceit or a failure to implement routine practices and controls to ensure prompt notice on the part of the cedent.

Factual Background

In the early 1970s, ICSOP issued an excess umbrella policy to Kaiser Cement Corporation (Kaiser), with limits of $5 million per occurrence. The policy contained no aggregate limit of liability. The underlying primary policy had a $500,000 per occurrence limit and likewise contained no aggregate limit. ICSOP secured quota-share reinsurance from Argonaut. Under the certificate, Argonaut agreed to reinsure 20 percent of the ICSOP excess policy, or $1 million per occurrence. The certificate was issued and delivered in California. It contained a standard notice provision requiring ICSOP to give “prompt notice” to Argonaut of “any occurrence which in the companies’ estimate … might result in judgment in an amount sufficient to involve this certificate of reinsurance.” The certificate also granted Argonaut the right to associate in the underlying defense (as is almost universally the case).

In the early 1980s, Kaiser faced thousands of asbestos bodily injury lawsuits as a result of Kaiser’s asbestos-containing products. Other AIG companies, aside from ICSOP, had issued insurance to Kaiser, and some of those companies were involved in early claims-related activities and meetings. These other companies were aware of the ICSOP excess policy. Id. at 2-3.

In 2002, Kaiser’s primary insurer filed a cross complaint against ICSOP and other excess insurers. From 2004 to 2008, the parties to the underlying coverage litigation fiercely litigated the “number of occurrences” issue in the California state courts. This litigation resulted in a 2008 ruling that asbestos bodily injuries to claimants would be deemed multiple occurrences (or in any event more than a single occurrence). Id. at 3-4.

In 2009, ICSOP provided Argonaut with its first notice of loss under the certificate. Id. at 6. Meanwhile, between 2001 and 2009, Argonaut, unaware of the Kaiser claims, executed multiple commutation agreements with its retrocessionaires (i.e. Argonaut’s reinsurers). Through such commutations, Argonaut released roughly a quarter of its total retrocessional coverage. In the present litigation, Argonaut alleged that had it received timely notice from ICSOP, it would still have its retrocessional coverage or, alternatively, it would have sought a higher value for the reinsurance it commuted. Id. at 5. The court observed that the latter option was “more likely” based on the evidence submitted, but noted this issue could be further pursued in discovery. Id.

Choice of Law

Argonaut asserted that no conflict of law existed between New York and California law. ICSOP contended three specific conflicts existed.1 The court found the only potential conflict concerned constructive notice – specifically, whether constructive notice to a reinsurer is sufficient under New York law.2 Ultimately, the issue was deemed immaterial, as the court concluded that even if both jurisdictions recognized such notice as proper, ICSOP had failed to prove Argonaut had even constructive notice. Id. at 10. Noting “general uniformity in reinsurance law across jurisdictions,” the court determined that California law controlled but that it would likely draw on reinsurance case law and principles from other jurisdictions, including New York. Id. at 8. The court also noted that application of New York law “would not alter the outcome.” Id. The choice of law issue was significant because New York courts apply the “bad faith” exception to late notice, if applicable, but the exception is an open question in California, where the state courts have yet to weigh-in on this exception.

Late Notice Arguments

Argonaut asserted that ICSOP should have first provided it with notice in the late 1980s or in any event no later than April 2000. The court relied on Ins. Co. of the State of Pa. v. Associated Int’l Ins. Co., 922 F.2d 516 (9th Cir. 1990), in which the 9th Circuit interpreted an identical notice provision. In that case, the 9th Circuit also predicted the California Supreme Court “would apply the notice-prejudice rule to contracts of reinsurance.” Id. at 10 (quoting Associated, 922 F.2d at 525). The court concluded ICSOP’s notice obligation was triggered in 2002, when Kaiser first asserted a cross-claim against it, and that the notice in 2009 breached the notice provision under the certificate. The court also rejected ICSOP’s “constructive notice” argument predicated on Argonaut’s alleged knowledge of the claim under a different reinsurance agreement between Argonaut and ICSOP. Id. at 9-10.

Proof of Actual and Substantial Prejudice

Both New York and California law require a reinsurer to demonstrate actual and substantial prejudice to successfully invoke a late notice defense (the notice-prejudice rule is still only a “prediction” under California law, see Associated, supra).3 Id. at 10. To constitute prejudice an injury must be real and substantial, not remote or hypothetical. In this regard, a reinsurer’s lost right to associate, without more, is insufficient to constitute prejudice. Id. at 11. Only where the reinsurer demonstrates the results of the litigation would have been materially different with its participation will such an argument suffice. Id.

The court held that Argonaut submitted sufficient evidence to raise a genuine issue of fact as to whether it was prejudiced in at least two ways. First, Argonaut might be able to establish its association in the defense would have resulted in an earlier and more advantageous settlement. Indeed, ICSOP’s counsel had chosen not to advocate for a “number of occurrences” position for various reasons, and the court noted Argonaut had significant experience with such issues due to its own litigation of similar issues during the relevant time. As such, the court concluded “Argonaut may demonstrate prejudice as a result of being denied an opportunity to encourage an earlier and more advantageous settlement.” Id. at 12.

Second, Argonaut could attempt to prove its commutations with its own reinsurers would have been materially impacted. Argonaut’s vice president testified that earlier notice of the claim would have resulted in a higher price for the commutations entered into from 2001 to 2009. ICSOP disputed this, highlighting the fact that IBNR (i.e. incurred but not reported claims) is already a component of the commutation calculations. The court held that it was at least unclear from the record whether the commutation prices and calculations would have been affected by the timely receipt of notice in 2002. Id. at 12.

The Bad Faith Exception to the Notice-Prejudice Rule Under California Law

Most notably, the court predicted that the California Supreme Court would adopt the so-called bad faith exception to the notice-prejudice rule. This exception derives from the 2nd Circuit’s seminal ruling in Unigard II in which it observed that a “very high level of good faith – whether or not designated ‘utmost’” is required due to the reliance a reinsurer must place on its cedent to fully disclose all material facts and information about a given risk. See Unigard Sec. Ins. Co. v. North River Ins. Co., 4 F.3d 1049 (2d Cir. 1993). Given this high level of good faith, if a reinsurer demonstrates either the deliberate deceit of a cedent or the cedent’s failure to implement practices and controls to ensure prompt notification of claims, the reinsurer is excused from proving prejudice. Id. at 13 (discussing rationale in Unigard II).

While California courts have not yet addressed the bad faith exception to the notice-prejudice rule in the reinsurance context, the court concluded it was possible to predict how the California Supreme Court would rule. First, provisions of the California Insurance Code set forth requirements related to a reinsured’s duty to convey all material risk information to a reinsurer – a key component of the rationale for the exception in Unigard II. Id. at 14. Second, California courts recognize reinsurers are sophisticated parties familiar with the practices of timely notice. As such, requiring prompt notice on parties already familiar with and dependent on such notice in their routine business is “minimally burdensome and consistent with the expectation of the parties entering into a reinsurance agreement.” Id.

The court rejected ICSOP’s argument that the California Supreme Court was unlikely to adopt the bad faith exception based on different historical standards governing late notice in the direct insurance context. The court relied on Certain Underwriters at Lloyd’s London v. Home Ins. Co, 783 A.2d 238 (N.H. 2001), in which the New Hampshire Supreme Court noted the difference in approaches taken by New York and New Hampshire courts in the direct insurance context concerning late notice, but observed that a “trend in modern case law” requiring “a very high level of good faith is required … particularly applies to reinsureds [to] timely notify[ ] reinsurers of potential claims.” Id. (quoting Certain Underwriters).

The court went on to list other reasons to “discount any difference” regarding the notice-prejudice rule between the two jurisdictions in the direct insurance context. These reasons included the rationale that a bad faith exception avoids technical forfeitures of coverage due to the gross negligence or deliberate deceit required, i.e. high standards of proof, and also due to differences in the structure and purpose of reinsurance versus direct insurance. Id. at 15. Finally, the court rejected ICSOP’s reliance on case law from the 7th Circuit, in which the 7th Circuit declined to apply a bad faith exception under Wisconsin law. Id.; See Zenith Ins. Co. v. Employers Ins. of Wausau, 141 F.3d 300 (7th Cir. 1998). For these reasons, the court predicted that the California Supreme Court would adopt the bad faith exception. Whether this exception applied, however, was to be pursued further in discovery and eventually trial.

Conclusion and Recommendations

ICSOP illustrates that there is growing consensus across the jurisdictions regarding reinsurance jurisprudence. Courts are increasingly holding cedents to their manifold duties, as set forth in their treaties and certificates. Late notice, historically regarded as a secondary or tertiary defense to payment, is more frequently grounds for voiding or reducing reinsurance coverage. As such, cedents should be mindful of their specific contractual notice obligations.

1 “Specifically, ICSOP contended that (1) under California law the reinsurer must always demonstrate prejudice from late notice, even if the reinsured acted in bad faith by failing to give timely notice; (2) California's standard for prejudice is more demanding; and (3) California law recognizes constructive notice.” Id. at 7.

2 The court explained that, under New York law, “it is well established that an insured may not rely on the doctrine of constructive notice.” Id. at 10. It was unclear to the court whether the doctrine of constructive notice would likewise be unavailable in the reinsurance context. Ultimately, however, California law controlled, and California law allows for constructive notice to an insurer. Id. at 9.

3 Under New York law, where notice is expressly made a “condition precedent” to coverage, a reinsurer will be excused from proving prejudice. See, e.g., Folksamerica Reins. Co. v. Republic Ins. Co., 2003 U.S. Dist. LEXIS 21162 (S.D.N.Y. Nov. 25, 2003), vacated on other grounds, 182 Fed. Appx. 63 (2d Cir. 2006); Constitution Reins. Corp. v. Stonewall Ins. Co., 980 F. Supp. 124 (S.D.N.Y. 1997), aff’d, 182 F.3d 899 (2d Cir. 1999). For obvious reasons, reinsurance litigation often concerns whether a notice provision is an express “condition precedent” to coverage.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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