Playing with House Money How to Trigger Insurance Coverage Kimberly W. Geisler

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1 I. EPLI Generally Playing with House Money How to Trigger Insurance Coverage Kimberly W. Geisler Employment practices liability insurance ( EPLI first emerged on the scene in the late 1980s due to the fact that most general commercial liability polices do not cover employment claims. 1 While EPLI initially only covered the costs of defense of wrongful termination claims, by the early 1990s, policies began to cover discrimination and sexual harassment claims and started providing indemnity in addition to coverage for the cost of defense. 2 New federal employment laws enacted in the 1990s, such as the Civil Rights Act of 1991, the Americans with Disabilities Act, and the Family and Medical Leave Act, led to an increase in federal employment claims and an increased need for employers to protect themselves from the risk associated with such claims. 3 Today, EPLI has become a key form of risk management for employers. A. Who Is Covered & When Is Coverage Triggered? EPLI coverage typically extends to the covered business entity itself, as well as its officers, employees, and former employees. Some EPLI policies may cover leased employees and independent contractors. Coverage is triggered by a lawsuit, an administrative complaint, an arbitration claim, or a simple demand letter. Oral demands are usually insufficient to trigger coverage because of uncertainty as to proof and timing. 4 When a claim is first presented in the form of a lawsuit, the claim is deemed to be made upon the insured s receipt of the summons or similar process. 5 B. What Is Covered? Modern EPLI policies tend to cover a wide range of employment claims, including 1 wrongful termination (including constructive discharge and retaliatory discharge, 2 discrimination, and 3 retaliation. 6 In addition, some policies contain a catch-all category to provide coverage for claims of discrimination based on protected categories (i.e., sexual orientation that are not covered under federal discrimination statutes but may be covered by state or local law. 7 Most EPLI policies also provide coverage for various forms of harassment and alleged violations of the Family and 1 Joseph P. Monteleone, Employment Practices Liability Insurance, in PRACTITIONER S GUIDE TO THE DEFENSE OF EPL CLAIMS 1,1 (Ellis B. Murov ed., 2005; Jeffery P. Klenk, Emerging Coverage Issues In Employment Practices Liability Insurance: The Industry Perspective On Recent Development, 21 W. NEW ENG. L. REV , 333 ( Montelone, supra note 1, at 1. 3 Montelone, supra note 1, at 2; see also L. Kathleen Chaney, Employment Practices Liability Insurance, 30 COLO. LAW. 125, 125 (2001 ( The rapid expansion of the EPLI market is attributable to a steady increase in the frequency and severity of employment related claims over the last decade.. 4 Montelone, supra note 1, at 8. 5 Id. at Montelone, supra note 1, at Id.

2 Medical Leave Act. 8 EPLI policies typically exclude coverage for the following types of claims: 1 workers compensation, 2 ERISA, 3 unemployment compensation, 4 COBRA, 5 wage and hour, 6 National Labor Relations Board decisions, and 7 breach of contract. 9 The list of exclusions in EPLI policies generally includes claims for bodily injury and property damage, but the EPL insurer will often cover claims for mental anguish or emotional distress associated with covered losses. 10 EPLI also generally excludes coverage for liability arising out of intentional wrongdoing. C. Liability Limits An important aspect of EPLI is that coverage for defense expenses is usually part of the liability limit. Thus, lawyers defending EPLI claims face the challenge of adequately representing the insured while knowing that every billable hour spent eats into the amount of coverage available for indemnification of any future settlement or judgment. 11 Further, defense expenses under an EPLI policy are usually subject to a self-insured retention (or deductible. Many insurers will set minimum retention amounts in order to avoid exposure to routine, non-severe claims. 12 Most often, there is an inverse correlation between the amount of the self-insured retention and the amount of the premium. EPLI provides coverage for damages in excess of the retention arising out of any employment practices for which the policy provides coverage, which includes judgments, settlements, back pay and front pay awards, pre-judgment and post-judgment interest, attorneys fees and costs, and defense expenses. 13 EPLI polices typically exclude coverage for wages, salaries, benefits or expenses of the insured; punitive damages (unless coverage is permitted by applicable state law; fines, penalties, or taxes; amounts due under an express employment contract; stock options and deferred compensation; and injunctive relief (i.e., reinstatement, providing ADA accommodations. 14 Additionally, in order to enjoy coverage, damages must stem from claims made by parties enumerated in the policy. 15 It is also important to note that most EPLI polices define each employment practice as one claim, so if more than one person makes a claim for the same employment practice, the coverage available under the policy to pay those claims will be limited to a single limit of liability Id. 9 Chaney, supra note 3, at 127; A Guide to Employment Practices Liability Insurance, THE WORKING PAPER (Phillips Lytle LLP, New York, N.Y. March 2007, at 2 [hereinafter The Working Paper]. 10 Montelone, supra note 1, at The Working Paper, supra note 9, at Chaney, supra note 3, at Chaney, supra note 3, at 126; Montelone, supra note 1, at Montelone, supra note 1, at Chaney, supra note 3, at Id. 2

3 I. EPLI From the Perspective of the Employee s Counsel A. Triggering Coverage Since it would be difficult to obtain an employer s EPLI policy before litigation commences, the employee s attorney should be familiar with which types of claims are generally covered by EPLI policies within the jurisdiction in which the employee is filing suit and should plead accordingly in order to trigger coverage. 17 For instance, if the employee has a strong FLSA claim but a weak race discrimination claim, the attorney should include both claims in order to invoke EPLI coverage, as the race claim would be covered by most policies whereas the FLSA claim would not be. Once coverage is triggered, the plaintiff-employee must determine his or her strategy. One strategy is to aggressively pursue litigation in order to burn up the employer-defendant s deductible as quickly as possible, so as to pressure the defendant-employer into settling. 18 Another strategy is to proceed slowly so that the defendant-employer does not go over its limit on its policy and cut into available settlement funds. 19 B. Pros and Cons of Invoking Coverage Ordinarily, it is advantageous for a plaintiff to try to invoke EPLI coverage, the idea being that if an insurance company is involved, there may be more money to throw into the settlement pot. On the other hand, there may be reasons for avoiding the invocation of coverage. For instance, a small employer without the benefit of insurance coverage may be intimidated into an early settlement to avoid the uncertainties of litigation. Likewise, a large employer with deep pockets may be willing to pay a higher settlement to protect its reputation, whereas an insurer may influence the employer to focus on cost savings. III. EPLI from the Defense Counsel s Perspective A. Ethical Issues Arising from the Tripartite Relationship Counsel retained by EPLI carriers to defend employment claims for their policyholders face a variety of challenges arising out of the tripartite relationship between the attorney, the insurer, and the policyholder. While all three parties in the relationship share the basic goal of defending the claim, the insurer and the insured may disagree about how the claim should be defended. Defense counsel is often placed in the middle, trying to balance the interests of the insurer and the insured. 17 Stephanie D. Gironda, EPLI Coverage: Practical Considerations From A Plaintiff s Perspective, available at dam.pdf. 18 Id. 19 Id. 3

4 1. Who Is the Client? Depending on the jurisdiction, counsel will either have one client (the insured or two clients (both the insured and the insurer. Most jurisdictions in the United States follow the Two-Client Theory, meaning that both the insured and the insurer are clients of the defense attorney. 20 The Two-Client Theory is based on the premise that most cases settle quickly within policy limits and that conflicts of interest are not likely to occur. 21 The substantive law in most two-client states provides that the insured is the primary client. A growing minority of jurisdictions follow the One-Client Theory, which provides that the insured is the attorney s only client. 22 Supporters of the One-Client Theory argue that allowing an insurer to have an attorney-client relationship weakens the attorney s loyalty to the insured. 23 Counsel should familiarize themselves with the applicable rules in the jurisdictions in which they practice. 2. Who Controls the Defense? Given that it pays for the defense, EPLI policies usually allow the insurer to control costs through the use of litigation management guidelines. EPLI carriers also routinely use internal or external auditors to review legal bills to insure compliance with litigation management guidelines. Given their detailed requirements, billing guidelines can influence judgment as to how the litigation should be conducted. The ABA advises that an who attorney believes that his or her professional judgment is being impaired by litigation guidelines should consult with both the insured and the insurer. 24 In the event of a conflict, the insurer can agree to withdraw or modify the offending guideline or the insured can agree to the limited representation. If the three parties cannot agree on the manner in which the defense should be prosecuted, the resulting conflict between the insurer s directives and the insured s immediate interests requires the lawyer to withdraw from representing the insurer and to protect the immediate interests of the insured in the litigation Who Controls Settlement? Traditionally, EPLI policies gave the insurer the exclusive right to settle covered claims. However, as employers increasingly demanded more control over settlement, insurance carriers began to include hammer clauses in their policies, which provide that if the insurer can obtain 20 Amber Czarnecki, Ethical Considerations Within the Tripartite Relationship of Insurance Law-Who Is The Real Client?, 74 DEF. COUNS. J. 172, 174 ( Id. at Id. at Id. (citing Atlanta Int l Ins. Co. v. Bell, 475 N.W. 2d 294 (Mich Ellis B. Murov, Ethical Issues Arising Out of Defense of Claims Under Employment Practices Liability Policies, in PRACTITIONER S GUIDE TO THE DEFENSE OF EPL CLAIMS 303, 306 (Ellis B. Murov ed., 2005 (citing ABA Comm. on Ethics and Prof l Responsibility, Formal Opinion Id. 4

5 an opportunity to settle, that is, an offer that the plaintiff has stated he or she would accept, then, if the insured refuses to consent to the insurer settling the claim, the insurer s liability under the policy will be capped at the amount of the foregone settlement plus defense expenses incurred through that point in time. 26 A hammer clause permits the insured to object to a settlement opportunity, but it requires the insured to bear the cost of making a bad decision. 27 Some hammer clause provisions are less severe in that they only require the insured to pay a percentage of the defense costs beyond the rejected settlement amount. 28 Often, there is tension between the insurer s desire to settle quickly and cost-effectively and the insured s desire to fight the claim in employment-related cases. Conversely, an insured may want to settle quickly in order to avoid embarrassment while the insurer would like to pursue litigation. The insured can be especially resistant to settlement if the settlement amount is within the self-insured retention. Difficult situations can also arise when a settlement requires the employer to reinstate a terminated employee. Counsel should keep in mind, however, that the insured always retains the right to reject the defense offered by the insurer. Indeed, lawyers who participate in settlement against the insured s wishes have been held liable for malpractice. 29 A lawyer faced with a irreconcilable conflict between the insured and the insurer over settlement may be left with no choice but to withdraw. However, as a practical matter, insurance examiners are business-minded in terms of relationships with employer-clients, and in most situations, if defense counsel has given a candid assessment of the case s strengths and weaknesses, all parties can eventually reach a consensus as to settlement. B. The Clash Between Insurer and Insured when there is a Reservation of Rights Frequently, a complaint filed against an insured will state both covered and non-covered claims or be written in such a way that it is not possible to determine whether a particular policy exclusion applies. In such situations, the insurer may elect to defend the claim under a reservation of rights, which allows the insurer to comply with its defense obligations without waiving its right to withdraw the defense at a later date [or] its right to refuse indemnity for non-covered claims. 30 Reservation of rights can present challenges for defense counsel. For example, in cases that involve both covered and non-covered claims, should counsel follow the insurer s instructions to seek dismissal of covered claims even if doing so would destroy the basis for coverage? Dismissal of the covered claims would almost certainly cause the insured to assume defense costs. On the other hand, leaving covered claims that are ripe for dismissal in play could jeopardize counsel s long-term relationship with the insurer. Counsel facing this situation may be forced to withdraw if the insurer 26 Montelone, supra note 1, at Klenk, supra note 1, at Thomas E. Deer, Settlement Issues and Strategies for EPL Claims, in PRACTITIONER S GUIDE TO THE DEFENSE OF EPL CLAIMS 265, 267 n.5. (Ellis B. Murov ed., Murov, supra note 24, at 321 (citing cases. 30 Stephen E. Whitehead & Jennifer W. Hall, The Insurance Tripartite Relationship: Who Is My Client Anyway?, 69 ALA. LAW. 416, (

6 refuses to retract its instructions to seek dismissal Enhanced Policy of Good Faith Some states, while allowing an insurer defending under a reservation of rights to control the defense, impose an enhanced duty of good faith on the insurer. In Alabama, for example, the enhanced duty of good faith imposes the following requirements on insurers: 1 Thoroughly investigate the claims asserted against its insured; 2 Fully inform the insured of all developments relevant to policy coverage; 3 Allow the insured to make the ultimate choice regarding settlement; and 4 Pursue a course of action that is advantageous to the insured. 32 An insured s failure to follow these requirements can constitute a forfeiture of coverage defenses Other Theories Some states view a reservation of rights as presenting an inherent conflict of interest and allow the insured to reject the defense offered by the insurer under a reservation of rights and select its own independent counsel to be paid for by the insurer. 34 Other states do not presume that a reservation of rights presents a conflict, but allow for independent counsel if a conflict is presented by the facts of a particular case. 35 For example, California law requires an insurer offering a defense under a reservation of rights that presents a conflict, as determined by a fact-specific test, to provide independent counsel to defend the insured at the insurer s expense, unless the insured waives, in writing, the right to independent counsel after disclosure of the conflict. 36 Conversely, Florida assumes that a reservation of rights presents a conflict of interest and requires the insurer either to: (1 obtain a non-waiver agreement from the insured after full disclosure of the specific facts and policy provisions upon which the coverage defense is asserted and the duties, obligations, and liabilities of the insurer during and following the pendency of the subject litigation or (2 retain independent counsel which is mutually agreeable to the parties. 37 Counsel should familiarize themselves with the applicable rules in the jurisdictions in which they practice. 31 Morov, supra note 24, at Whitehead & Hall, supra note 30, at 418 (citing L&S Roofing Supply Co., Inc. v. St. Paul Fire & Marine Ins. Co., 521 So. 2d 1298 (Ala See also Tank v. State Farm Fire & Cas. Co., 715 P. 2d 1133 (Wash Whitehead & Hall, supra note 30, at William T. Barker, Insurer Control of Defense: Reservation of Rights and the Right to Independent Counsel, 71 DEFENSE COUNSEL J. 16, ( Id. at Whitehead & Hall, supra note 30, at 418 (citing CAL. CIVIL CODE Id. (quoting Section of the Florida Claims Administration Statute. 6

7 V. Theory into Practice Mock Complaint Attached is a mock complaint designed to illustrate the issues faced by both plaintiffs and defendants regarding EPLI coverage

8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION BECKY BARKLEY, on behalf of herself and all similarly situated individuals v. Plaintiff, PET WORLD, INC., Defendant. CIVIL ACTION NO. COMPLAINT COMES NOW the Plaintiff, Becky Barkley, by and through the undersigned attorney, on behalf of herself and all similarly-situated individuals, and states the following: I. JURISDICTION 1. This action for injunctive relief and damages is brought pursuant to the Fair Labor Standards Act, 29 U.S.C. 201, et seq ( FLSA and pursuant to the Family and Medical Leave Act of 1993, 28 U.S.C. 2601, et seq ( FMLA. District Court jurisdiction exists pursuant to 29 U.S.C. 216(b, id. 217, and 28 U.S.C The jurisdiction of this Court is invoked to secure protection for and to redress the deprivation of rights and Defendant s violation of the Acts and for injunctive relief and damages.

9 II. PARTIES 2. Plaintiff Becky Barkley (hereinafter Plaintiff is a citizen of the United States and a resident of Hoover, Jefferson County, Alabama. Plaintiff was formerly employed by Defendant at its location in Hoover, Jefferson County, Alabama. Plaintiff was an employee within the contemplation of 29 U.S.C. 203(e(1. Thus, pursuant to 28 U.S.C. 1391(b, venue for this action properly lies in the Northern District of Alabama, Southern Division. 3. Defendant Pet World, Inc. ( Defendant or Pet World is a California corporation with corporate headquarters located in Eureka, California. Pet World has numerous locations throughout the United States, including a location in Hoover, Alabama. Defendant is an entity subject to suit under 28 U.S.C and 29 U.S.C. 2617(a(2. Defendant employs at least fifty (50 persons and is an enterprise as contemplated by 29 USC 203(r. Therefore, this Court has personal jurisdiction over Defendant. III. COUNT ONE: FLSA VIOLATIONS 4. Plaintiff hereby incorporates by reference each and every material averment contained in paragraphs 1 through 3 above as if fully set forth herein. 5. At all times relevant, Plaintiff and those similarly situated to Plaintiff were employed by Pet World as exempt Assistant Managers. As exempt 2

10 Assistant Managers, Plaintiff and those similarly situated to Plaintiff worked the cash registers, monitored the cleanliness of the store, stocked shelves, and greeted customers. Plaintiff and those similarly situated to Plaintiff were not granted authority to supervise, hire, fire, or promote other employees. In fact, Plaintiff and those similarly situated to Plaintiff did not perform any managerial functions whatsoever the term manager was utilized by Pet World in an attempt to avoid paying Plaintiff and those similarly situated to Plaintiff the overtime compensation to which they were rightfully entitled. Accordingly, Plaintiff and those similarly situated to Plaintiff were improperly classified as exempt employees by Pet World. 6. Plaintiff and those similarly situated to Plaintiff were paid a salary in the range of $30,000-$40,000 per year. Plaintiff specifically was paid $35,000 per year. 7. Plaintiff and those similarly situated to Plaintiff regularly worked over 40 hours in a work week. Plaintiff and those similarly situated to Plaintiff worked numerous overtime hours and lunch periods without being paid overtime wages. Pet World, however, did not pay Plaintiff and those similarly situated to Plaintiff for all hours worked in order to avoid overtime payments. 8. Pet World has failed and continues to fail to meet the requirements of the FLSA by instituting policies and engaging in practices that violate the overtime pay and record keeping provisions of the FLSA. Specifically, Pet World has violated 3

11 these provisions by: a requiring, suffering, and/or permitting Plaintiff and those similarly situated to Plaintiff to work on holidays, weekends, and after regular work hours and failing to record or pay overtime for the time worked; b requiring, suffering, and/or permitting Plaintiff and those similarly situated to Plaintiff to work hours off the clock throughout their work day and failing to record or pay wages for hours worked, and by engaging in a policy or practice of reducing hours on employees time records; c requiring, suffering, and/or permitting Plaintiff and those similarly situated to Plaintiff to perform work during their meal periods despite deducting those meal periods from the employees hours; d violating the record-keeping provisions of the FLSA by failing to properly record hours worked; and e failing to properly calculate the overtime rate by, among other things, failing to record or pay wages for all hours worked and failing to pay overtime premiums at one and one-half times the employees regular rate of pay as required by law. 9. The named representative, Plaintiff, as well as all others similarly 4

12 situated to Plaintiff, present and/or former employees of Pet World were and/or are subject to the policies, conduct, and practices of Pet World set forth above and, as a result, their number of hours worked as recorded by Pet World were far less than their actual number of hours worked. 10. Pursuant to Pet World s policies and practices, Pet World has failed and continues to fail to pay Plaintiff and those similarly situated to plaintiff the required overtime premium pay of one and one-half times their regular rate of pay for all hours worked in excess of 40 per work week. 11. As a result of the overtime pay and record keeping violations of the FLSA, the named representative, Plaintiff, as well as those similarly situated to Plaintiff, have suffered damages by failing to receive their lawful wages during their tenure of employment with Pet World. In addition to the amount of unpaid wages, Plaintiff and those similarly situated to Plaintiff are also entitled to an additional amount as liquidated damages pursuant to 29 U.S.C. 216(b and/or prejudgment interest. 12. Plaintiff and those similarly situated to Plaintiff are also entitled to an award of attorneys fees pursuant to 29 U.S.C. 216(b. 13. Pet World s actions in failing to compensate Plaintiff and other similarly situated employees of Pet World in accordance with the provisions of the FLSA were 5

13 willful and not in good faith. 14. There are numerous other similarly situated employees and former employees of Pet World who have been improperly classified and thus improperly compensated in violation of the FLSA and who would benefit from the issuance of court-supervised notice of the present lawsuit and the opportunity to join the present lawsuit. Specifically, all employees and former employees of Pet World who have been employed by Pet World as non-exempt Assistant Managers in any facility owned and/or operated by Pet World, including their stores in Hoover, Alabama; Wasilla, Alaska; Eureka, California; Bowling Green, Kentucky; Bangor, Maine; Worcester, Massachusetts; Crookston, Minnesota; Tupelo, Mississippi; White Fish, Montana; Toledo, Ohio; Hershey, Pennsylvania; Waco, Texas; Olympia, Washington; and Charleston, West Virginia should receive notice and the opportunity to join the present lawsuit. WHEREFORE, PREMISES CONSIDERED, the named representative, Plaintiff Becky Barkley, individually, and on behalf of all other similarly-situated persons, pursuant to 29 U.S.C. 216(b, prays for the following relief: a that the Court issue notice to all similarly-situated persons; b that other similarly situated past or present employees be given the opportunity to join this lawsuit as party-plaintiffs by filing written 6

14 consent pursuant to 29 U.S.C. 216(b; c that Plaintiff, and all others who file consent, be awarded damages in the amount of their unpaid wages, an additional equal amount as liquidated damages pursuant to 29 U.S.C. 216(b, and/or prejudgment interest; d that Pet World be required to pay Plaintiffs attorneys fees; e that Pet World be required to pay the costs and expenses of this action; and f that Plaintiff and all others who file consents be granted such other, further, and general relief to which they may show themselves entitled. IV. COUNT TWO: FMLA INTERFERENCE 15. Plaintiff hereby incorporates by reference each of the allegations contained in paragraphs 1 through 14 above as if fully set forth herein. 16. On or about December 16, 2011, Plaintiff reported to work, as usual. Around 2:00 p.m., Plaintiff received a call while she was at work that her dog, a brown Standard Poodle named Stefan, was being taken to the emergency vet after he suddenly fainted and entered into a coma. 17. Plaintiff followed proper protocol by contacting her supervisor, Ron Katz ( Katz, and telling him that an emergency had arisen and the basis of the emergency. 7

15 18. Katz gave Plaintiff authority to leave immediately to care for Stefan. Plaintiff left and drove immediately to the emergency vet. 19. Stefan remained at the emergency vet for five days in critical care. During this time, Plaintiff never left his side. The vet told Plaintiff that it was her continuing presence that brought Stefan out of his coma. 20. Defendant did not provide Plaintiff any FMLA paper work in order to account for her time absent to be treated as FMLA leave time, despite the fact that Defendant was aware of Plaintiff s FMLA qualifying need. 21. On December 18, 2011, Plaintiff received a call from Katz and was informed that her employment with Defendant was terminated, effective immediately. Plaintiff was shocked by Katz s lack of compassion, especially given that it is his job to work with and be sympathetic towards pets on a daily basis. 22. Plaintiff s employment was terminated while she was off on FMLA qualifying leave. Defendant intentionally and willfully violated the FMLA by terminating Plaintiff s employment, causing damage to Plaintiff. 23. As a result of Defendant s violation of the FMLA, Plaintiff has been damaged, suffering loss of pay and benefits. 8

16 WHEREFORE, PREMISES CONSIDERED, Plaintiff seeks an award of compensatory and liquidated damages, attorneys fees and costs, and any additional relief as may be determined by the Court to which Plaintiff is entitled. OF COUNSEL: LAW FIRM, P.C. 999 Law Street Birmingham, Alabama Telephone: ( JURY DEMAND Attorney Counsel for Plaintiff Becky Barkley Plaintiff demands a trial by struck jury for the trial of this cause. SERVE DEFENDANT: Pet World, Inc. c/o Steve Fox Registered Agent Pets Drive Eureka, California Attorney Counsel for Plaintiff Becky Barkley

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