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It’s a strange time with the Coronavirus. I have been reading a lot about it and monitoring what's been going on in the world, the U.S. and our Community. Scary, and it hasn't fully hit us yet. I hope our leaders step up to lead us in this time and pray our community can take care of our sick.
It’s a bit of a mad whirlwind of event and sports cancellations, changing information about how to protect ourselves and our families, and how to go on with a normal life amid this pandemic. As you don't need my views on this, I'll try to keep it a bit normal with my regular bi-weekly email.
Our firm has established plans to work remotely and stay in business if super restricted travel becomes necessary. So, we will keep working hard for our clients and are here for questions and help from lawyers and new clients.
Stay healthy.
Deposed a defendant last week who refused to admit she did anything wrong. She was driving her commercial vehicle, went too fast, slid on ice and snow, spun out perpendicular to the road, went across the road and crashed head on into my client's truck.
He had seen her coming and pulled to the side of the road and stopped by then. Pictures show the road completely icy. She flat out refused to admit she did a single thing wrong. The problem is, her lawyer is likely to admit liability in the opening statement to defuse the situation at trial. What to do? Here it is in three steps:
All my evidence of negligence will come in. And it’s some old, good law – back to 1934.
Most recently in Ingram v. Rinehart, 108 S.W.3d 783 (Mo. App. W.D. 2003), defendant admitted liability but the trial judge allowed counsel for plaintiff to present evidence of fault including direct and demonstrative evidence that the defendant was drunk at the time of the incident, testimony about what led up to the incident itself and its aftermath, and photographs of the incident scene.
The Court said:
”The party bearing the burden of proof is not bound to a party's admission. Franklin v. Byers, 706 S.W.2d 230, 231 (Mo. App. 1986); Ruppel v. Clayes, 72 S.W.2d 833 (Mo. App. 1934). Instead, that party may elect to present evidence to prove the issue at a jury trial. Ruppel, 72 S.W.2d at 835. Furthermore, that testimony and evidence was also admissible because it was directly relevant to the disputed issues regarding plaintiff's special damages and their claim for punitive damages. There was no error admitting the challenged testimony and evidence.”
The rationale underlying this long-standing rule in Missouri is that "[a] colorless admission by the opponent may sometimes have the effect of depriving the party of the legitimate moral force of his evidence . . . " Wigmore on Evidence, 3d Ed. § 2591.
Back in 1934, the Ruppel v. Clayes, 72S.W.2d 833, 835, 836 (St. L. 1934), court held that even when a defendant makes an unqualified or limited admission of liability, a plaintiff has the right to introduce evidence relevant to the issue of liability. The court said:
“[p]arties, as a general rule, are entitled to prove the essential facts, to present to the jury a picture of the events relied upon. To substitute for such picture a naked admission might have the effect of robbing evidence of much of its fair and legitimate weight. No exception lies to the admission of relevant evidence under such circumstances.”
Thanks to my friend Tim McCurdy for his great presentation last Friday. I enjoyed mine as well. Here are some reviews:
If you would like the materials from the CLE, go to our lawyer to lawyer page here. They are all there for free.
Burger Law is dedicated to giving back to the community, and for 2019 we present a new Scholarship Essay Contest! In our previous scholarship competition, we awarded a scholarship to the top entry.
Kate Kouplen from Jenks, Oklahoma had a great essay and idea on how to stop texting and driving and won the $1500 scholarship.
This year our top entry will be awarded $2000! The essay question for this year is – How to STOP Bullying.
There’s no easy answer to this problem, but it’s a question deserving of the inquiry. Bullying can have serious and traumatic effects on children and even adults, and it’s never ok nor acceptable. But why does it start? How can an age-old problem be stopped? We’re excited to see what solutions our scholarship candidates can put forth, and what new ideas they have to stop bullying.
Our coronavirus pandemic continues. With the mandatory stay at home order in place in St. Louis, my family and I are staying home and working from home.
We closed the physical office of Burger Law last Tuesday and moved everyone to working from home. My kids started virtual school this week. So much to worry about and so many things changing.
Remember you only can control what you can control and this too shall pass. Here's an update about Burger Law and corona, a video a great client texted me, and a helpful list of court orders in light of Covid-19.
With the coronavirus, it seems like things are changing rapidly, but Burger Law will not only keep up, but be ahead of the curve.
We remain open 24/7 to our clients and future clients who need our help. We offer phone and video counseling for all our clients and prospective clients.
We work on our clients’ cases continually and virtually and are able to sign new clients, file lawsuits, answer discovery, take depositions, mediate cases and take any legal action necessary.
Our modern firm has long been set up virtually. Cloud based case management, intake and email programs, internet phone system, off hours call service, a team of intake specialists, 100s of YouTube help videos, DocuSign practice of signing contracts, zoom meetings, large server with remote access has, as it turned out, helped us be a virtual firm long ago.
To keep our lawyer friends, clients and prospective clients updated, here’s some important points about Burger Law‘s business operations during the Covid-19 mandatory social distancing/staying at home orders:
We are currently setting video depositions and video mediations. We are busy answering client and lawyer questions about a case, potential case, referrals from the lawyers, our operations during the Covid-19 pandemic for any other concerns about our clients' cases.
For lawyers who are challenged in litigating cases during this time, we can help. Call us for litigation support and to co-counsel in cases at [wdac-phone].
Courts have closed all over the area. Here's an article on the Missouri Supreme Court's response to the pandemic.
How do you know what each one is doing? The Missouri Supreme Court has created a page to collect court specific responses, which you can find by clicking here. The Illinois Supreme Court's page can be found by clicking here. The Missouri Supreme Court has offered for April oral arguments to continue them, submit cases of the briefs or argue over video conferencing. What would you do?
It’s been 6 weeks since I closed my office and had our staff work from home. That's 60,480 minutes since March 17, but who's counting?
The firm and I have been incredibly busy. We unmanned our physical office in downtown St. Louis and have all of our staff working from home. We have access to all our client documents, and have scanners, computers and everything we need in our home offices.
I filed a brief and argued to the Missouri Supreme Court, started an “Ask a Lawyer” Facebook show, and have been working to manage my firm virtually. Best of all, I get to hang with the family more.
I think this quarantine is going to change how lawyers do business in the future – less of a need for court appearances and face to face meetings. It's going to change how we do a lot of things. Below I list my top 10 video conference moments, discuss the pandemic and nursing home rules. But first:
Because of the strange time we are in, the firm and I decided to start an “Ask a Lawyer” Facebook show once a week to field any legal questions people may have.
We also decided to give a $150 Insta-Cart gift certificate away every week to help families buy food who might need the extra help. Tune in Friday at 4 pm for this show - ask me some good questions.
The rapid advent of videoconferencing (for me) over the last month has been a game changer. Here's my top 10 moments:
Strictly following state and federal COVID-19 prevention regulations is the legal obligation of long-term care facilities to keep residents safe in the midst of infectious outbreaks.
Prevention measures for COVID-19 are the same strategies used to detect and prevent common viruses such as the flu. This includes hand washing, avoiding social contact, and not touching shared surfaces.
With elderly people being most at risk of contracting the virus, additional prevention measures must be enforced in nursing homes. Note that while nursing homes are a hotspot for infection, everyday contact for people both healthy and immunocompromised is dangerous.
If you or someone you know has questions about a nursing home coronavirus claim, please call me at [wdac-phone].
Below are some of the coronavirus prevention regulations to which long-term care facilities are required to adhere:
Elderly people are considered high-risk for many illnesses and conditions. With nursing home residents regularly getting sick, undergoing surgeries, receiving physical therapy, and getting treatments, it’s crucial for nursing homes to sanitize frequently.
According to the CDC, one of the most effective ways to prevent the spread of COVID-19 is to continually disinfect tables, chairs, and other surfaces. If a long-term care facility fails to take proper sanitary precautions, and a resident gets sick, this could result in a nursing home claim for loss of life.
Coronavirus spreads easiest via respiratory droplets and touch. As such, the CDC recommends that all people (especially nursing home caregivers, nurses, and doctors) wear face masks and gloves to prevent its spread. If a long-term care facility fails to provide gloves, face masks, face shields, and other supplies to nurses, doctors, and other caregivers, and a resident contracts COVID-19.
Isolation is one of the most effective ways of preventing a nursing home resident from infecting others. Isolation must be achieved as soon as an individual is suspected of having coronavirus – this is done through persistent surveillance by nursing home caregivers, nurses, and doctors.
If a patient is showing coronavirus-related symptoms such as dry coughing, running a fever, or having shortness of breath, staff should spot these signs immediately and follow COVID-19 prevention measures and isolate sick residents. Failure to isolate a nursing home resident that has been diagnosed with coronavirus, or is displaying symptoms, is nursing home negligence.
Federal COVID-19 nursing home regulations were updated on 4/13/2020. Per the update, nursing homes and long-term care facilities must prohibit all non-essential visitors and outside caregivers and physicians, such as hospice and EMS workers, dialysis specialists, etc.
Any staff or visitors that have a cough, fever, or other coronavirus symptoms are restricted from entering facilities. Lastly, group gatherings such as dining hall meals, religious services, and social activities, are strictly prohibited. These events are shown to be conducive to the spread of the virus. Nursing home residents must be isolated from all possible sources of infection whether they display symptoms or not.
Federal nursing home regulations mandate that long-term care facilities must utilize an Infection Control Program, which is designed to help each resident attain or maintain their highest level of well-being. Under these regulations, facilities must:
When investigating a potential coronavirus lawsuit against a nursing home or long-term care facility, we obtain a copy of the facility’s infection control record. This record should include potential coronavirus cases, as well as the steps that the facility took to prevent the spread of COVID-19.
Yes, it's Friday. The days seem to run together with working from home and the TGIF phenomenon is not there anymore.
Our country's navigation through this pandemic continues, with twists and turns. Even after three and a half years of this Administration, I am frankly surprised at the divisiveness over the coronavirus. People calling it a conspiracy and rebellion over health and safety recommendations. Here's a Facebook post I put up for my law firm:
”If you or your loved one has been refused entry to a business for failure to wear a mask or if you would like to protect your constitutional rights with the pandemic restrictions, my law firm would be happy to explain how selfish and misguided you are.”
We continue to be incredibly busy working from home. Cases settled, depositions, filed lawsuits, etc. We recently filed a national class action case against a private prison company, Management Training Corp, for not paying guards for pre- and post-shift activity.
And we will be reopening our physical location in a few weeks. Below I share our office policy for when we reopen – I would love to hear what everyone thinks about it. Feel free to use it as a model for your own business. I also discuss a $350,000 settlement below with a video of my client Randy and I. But first, I have been busy with my bees this spring, with adding two new hives, having a hive swarm and catching it.
Requeening a beehive refers to the hive making a new queen or a beekeeper changing queens. I did the former with two hives this year.
The first was by accident. I had bought and put together two new hives and was going to "split" my hives again. This means you split part of a bee hive off and the bees make a new queen.
But before I could, one of my hives swarmed. This is how bees reproduce – they naturally make one hive into two. The existing queen gathers about half the bees (a few thousand) and they leave the old hive and settle on a tree branch, log or wherever. They then look for a new home.
Meanwhile the hive where they left creates new queens. They start feeding the larvae "Royal Jelly" to change them from a regular bee to a queen. They make a bunch of queens. It takes 15 days to make a new queen. The first queen to hatch kills the other queens in their cocoon. Like in the movie Highlander – there can be only one. New queens sing to the hive.
So, I opened the hive from where the swarm came, and sure enough, they were making a bunch of new queens. But first I had to catch the swarm in the tree. So, I did. You do this by shaking the swarm into a hive box. Or so I've read – never did it before.
It went well. They kept going back to the tree, so I kept shaking them in the box. I was able to get the queen in there, so the rest of the bees followed within an hour or so.
These bees are thriving as is the hive they left. But I felt bad that all those new queens were being raised but only one would live. So, I collected a couple. Look for my next newsletter about what I did with them.
We filed and litigated an auto crash for Randy. He was rear-ended on highway 270 going to work. I've known Randy for 20 years. Truly a great guy. He was hit pretty hard.
Randy went through conservative therapy and eventually had surgery. In the video below, Randy and I talk about his case, why you should take pictures after a car crash and how we navigated his case.
We held out for the full policy limits of $250,000 from the person who rear ended him. They jerked us around for a while and I told the other lawyer and adjuster we would not take a dime under the policy limits. We also pursued and obtained $100,000 from his underinsured motorist policy. We put a lot of money in his pocket – tax free.
I also had the pleasure of representing Randy seven years ago in a trial in Jefferson County where we got a jury verdict of $142,000. He was riding a motorcycle when another driver pulled out in front of him. He had an open rotator cuff surgery and fully recovered.
At trial he testified he could paint (he is a great professional painter) as well as before and had worked hard to make a full recovery. His physical therapist loved him – he went to 52 of 52 physical therapy visits, and never missed one. So proud to represent Randy. As I joke in the video, I cannot wait for his next crash – three's a charm.
As we return to the office after the stay-at-home order, it is critical that precautionary measures are followed to continue mitigating the spread of COVID-19.
This provides guidelines for our staff to return to the workplace. The most effective tool for preventing the spread of the COVID-19 virus is physical distancing, but there are other measures we can take to stop the spread and provide a safe work space.
Remember that responses to the pandemic, best practices, and how we run our firm is rapidly changing, so the policies in here may change as well.
Please adjust your personal behavior to control the likelihood of exposure. Remember your responsibility to protect yourself and others by following protocols for minimizing risk of infection. Please see Gary if you cannot and special arrangements will be made for you to work from home.
Here's an update on me and the firm.
Time seems to be going slow and fast at the same time lately. While working from home, things slow down, I get to hang more with my wife and kids and be present with my family. I have been working out (biking and running) and doing stuff around the house – e.g., bee hive expansion discussed below.
Simultaneously, national news is a whirlwind – George Floyd death, Black Lives Matter protests, up and down corona and economic news, election cycle, and POTUS' hundreds of tweets. Below is a little article on my family marching (William and I made the news). And law firm activities are super busy - depositions and hearings by zoom, new lawsuits filed, trials continued to 2021 - I spend many evenings keeping up.
For all the lawyers, please attend our Zoom CLE in a couple weeks on Liens, ERISA and (de)Stressing. Register now. Three hours and the best title for the ethics hour – Love and Lawyering in the Time of Coronavirus.
In my last email, I talked about increasing the number of my hives. I had one hive swarm and captured the swarm into a new hive.
The old have made new queens. I took a couple of those queens in their cocoon and created yet another new hive – and it worked. I put the old queen cells into a new small box with some frames and let them sit for a couple weeks. This lets the new queen hatch and start running the hive. The bees accepted the new queen from a different hive. I could tell they accepted her and were building out new honey comb and she was laying new eggs. So, they were ready to move into a new box to expand.
So, I take the frames from the starter box and move them into a regular 10 frame hive box. It’s a great year for honey. The bees seem to be getting a lot of nectar and pollen. The " honey flow" should be beginning now. Honey flow is a time when one or more major nectar sources are in bloom and the weather is favorable for bees to fly and collect the nectar in abundance. Honeybees are fast – they visit up to about 40 flowers per minute depending on floral type, nectar availability and weather conditions.
A bee will visit 100–1000 flowers per trip from the hive. A single bee will do an average of 10 trips per day. A hive may have thousands of forager bees. A hive can gain 8 to 20 pounds in a single day. In two days, a strong hive with more than 20,000 foragers may fill a honey super. This is for nectar; ripe honey has its water fraction reduced significantly.
Fingers crossed.
This AMAZING ZOOM CLE will teach you all this and more. My Lien CLE is the top result when you google resolving liens in cases – go ahead and Google it – then register for this CLE, as I only do it twice a decade.
Phil Tatlow is the recognized ERISA expert in the area with hundreds of ERISA victories. The more is an hour of ethics credit on dealing with your and your client's stress and mental health – Love and Lawyering in the time of Corona. Brought to you by Dave Crawford and I. As usual, this will be a great nuts and bolts CLE and with robust written material.
Approved for 3 hours of Missouri and Illinois CLE Credit, including one hour of ethics.
P.S. - Love in the Time of Cholera has one of the best first lines of any novel: "It was inevitable: the scent of bitter almonds always reminded him of the fate of unrequited love”.
I am trying to answer people’s legal questions on a Facebook show we have been doing. Here's some new questions we answer on our website.
It’s important to teach your children well. We have taken the opportunity to stand up for what we believe and participate in peaceful protesting. William and I were interviewed and made it on the news!
Happy Independence Day (Saturday). We are closing our office Friday to let our attorneys and staff enjoy the holiday and a long weekend. Below I discuss a few settlements, our really successful Zoom CLE, an interview with the winner of our scholarship, and more Lawyer v. Lawyer Podcasts and a FB show.
But first, I thought I would give you 10 surprising facts about the Declaration of Independence:
While the declaration was adopted by the Continental Congress on the 4th, most of the men did not sign it until August 2nd of that year and New York delegates did not even give their support until July 9th.
July 2nd was when the Continental Congress voted on Independence and the day they thought would be remembered and celebrated as Independence Day.
Most people see the original Declaration on display at the National Archives in Washington, D.C. While it is the original, it is not the only one -- there were hundreds of copies made. These copies are known as the “Dunlap Broadsides”. They were used to spread the news of the Declaration throughout the colonies. The rebels had a great system of copying and disseminating information quickly.
In 1989, a Philadelphia man got very lucky when he found an original Dunlap Broadside copy in the back of a picture frame he bought at a flea market for $4. It sold for $8.1 million in 2000. What a find! A 26th known Dunlap broadside emerged at the British National Archives in 2009, hidden for centuries in a box of papers captured from American colonists during the Revolutionary War.
Thomas Jefferson, John Adams and James Monroe all died on the Fourth of July. Adams and Jefferson both died on the 50th anniversary of the Declaration’s passage. James Monroe died 5 years later on July 4, 1831.
Benjamin Franklin was the oldest signer at 70 years old. But 44 years his junior was Edward Rutledge, a lawyer from South Carolina who was only 26 at the time.
In the movie “National Treasure,” Nicholas Cage’s character claims that the back of the Declaration contains a treasure map written in invisible ink. That is not sure, but there is writing on the back. It reads: “Original Declaration of Independence dated 4th July 1776.” It’s thought this was added as a label, but no one is sure when.
The first time was when the British attacked Washington during the War of 1812, and the second time was during World War II from 1941 to 1944 when it was stored at Fort Knox.
Our client Cindy was involved in a three-car accident and we were able to recover multiple times for her. She and her husband Nick were on the way to work in Nick's work vehicle when they were rear ended on Highway 270. Cindy had to be taken to the hospital with back and neck pain.
Follow up imaging showed that the accident caused the hardware from a previous back surgery to move, and created new painful disc bulges. Cindy would need corrective surgery again to repair her back, but the incident was 4 and a half years ago and her medical damages at the time of settlement were only $11,000.
Even though Cindy was pain and symptom free for years, the Defendants argued that this was not related to the accident. We sued both other vehicles involved in the accident. We took the deposition of her surgeon, who confirmed the cost of surgery, the change to Cindy's back, and the likely lost time at work.
The week before trial, we recovered the policy limits from the rearmost driver, as well as additional settlement from the middle driver who was partially at fault, for a total of $57,000. Then we pursued the underinsured case. When the insurance company refused to pay, we sued them for vexatious refusal to settle. The case went to court ordered mediation, and we settled it for $300,000.
The hood of Marqual’s vehicle flew open as he was driving down the highway. In this moment, Mr. Patton’s life flashed before his eyes. His vision was completely obstructed due to the raised hood of the vehicle.
He lost control of the vehicle and his car was sent barreling into the median. This accident arose from the carelessness on the part of the company that had serviced Marqual’s vehicle. Specifically, employees of this car service failed to properly secure the hood after they completed work on the vehicle.
As a result, our client suffered severe injuries to his knees and back which required a ligament repair surgery and months of physical therapy and rehabilitation. Fortunately, this story has a happy ending. Marqual has fully recovered from the injuries that he sustained in the accident and the diligence and determination exhibited by those at Burger Law Firm helped to achieve compensation for him to the tune of $82,500!
Our third case we settled for $125,000 with Marqual’s only $6,259 in medical damages. In April 2018, our client was using her pressure cooker that she received as a gift from a large department store in the Illinois area. Our client had used her pressure cooker numerous times and was using it like she always had.
All of a sudden, the pressure valve malfunctioned, and our client opened the cooker without pressure being released and shooting hot water onto her stomach, side and legs. OWWWW. Unfortunately, it burned these parts of her body. Our client opted out of a class action litigation involving the pressure cooker and made this individual claim against the manufacturer.
The manufacturer was liable under the theory of product liability set forth in § 402A and 402B of the Restatement (Second) of Torts as the manufacturer engaged in the business of designing, manufacturing, selling, marketing and/or supplying these pressure cookers. The cooker was defective in that the pressure release – an essential safety feature – unlocked while the contents of the cooker were still pressurized causing injuries to our client.
The cooker was not reasonably safe for its intended use because it did not conform to its intended design and failed by allowing the lid to be opened when the Cooker contained pressurized steam and hot water. Without limitation, the cooker was defective because it did not perform as intended and designed.
Our client went directly to the emergency room. It was determined that she had 1st degree burns on approximately 7% of her total body surface.
The center of the scars were treated with vascular laser on short pulse duration and others were treated with CO2. She underwent this treatment 4 times. This was a painful injury that took a long time to heal. Even with the plastic surgery procedures, she still has permanent scarring from these burns.
We presented a great CLE two Fridays ago - attended by over 100 lawyers. Phil Tatlow presented on ERISA, I did a talk on resolving Liens, and Dave Crawford and I did an ethics session on dealing with stress during this strange pandemic time.
To access all the CLE written material and powerpoint slides, head here.
I was able to obtain a $3 million judgment against murderer Pamela Hupp on Friday.
I represent the family of Louis Gumpenberger. Hupp killed Louis on August 16, 2016, by shooting him. Margaret Burch, Louis' mom and grandma and guardian of Louis’ minor child testified in support of the judgment.
Margaret wanted to be sure that Pamela Hupp could not profit off of her crimes and her murder. If she tries, the first $3 million goes to Margaret and Louis’ son.
The details of Hupp's murder of Louis are grisly. Hupp called 911 shortly before shooting Gumpenberger. Hupp claimed that Louis, armed with a knife, had jumped out of a car (driven by another person) into her driveway, accosted her while she sat in her vehicle in her garage, and demanded she drive them to a bank to retrieve Russ Faria’s money.
She also stated this prompted her to flee into her house and then shoot Louis in self-defense with a gun she kept on her nightstand after he pursued her. Hupp planted a knife and a note on Louis' body.
The note contained instructions to "kidnap Hupp, get Russ's money from Hupp at her bank, and kill Hupp” and to "Take Hupp back to house and get rid of her. Make it look like Russ' wife. Make sure knife sticking out of neck." in return for a reward of $10,000. Russ Faria spent three years in prison, wrongly accused of his wife's Betsy's murder.
She even put $900 in Louis’ pocket. Then she stabbed herself in the neck and waited for the police to arrive. On June 19, 2019, Defendant Hupp entered an Alford guilty plea of the charges and was sentenced to life imprisonment without the possibility of parole for Louis' murder.
In her Alford plea, Hupp still did not admit to any criminal act relating to Louis. Hupp is incarcerated with the Missouri Department of Corrections.
We were hired more than three years after Louis’ death by his mom. We filed a Petition and served her in prison. For reasons set out in the article below on the wrongful death three-year statute of limitation, we alleged fraud and concealment.
We had some delays because of service, a judge recusing himself because of involvement in past cases with Hupp and corona. Hupp never got a lawyer or filed an answer. Margaret and I went to Court on Friday and obtained a judgment against Hupp for $3 Million. Unlike a typical hearing like this, Margaret testified about her son, the murder, her sorrow and anger and the impact on her grandson.
I was not sure how much the court wanted to hear but the Judge said "Let her talk." It was incredibly moving. Not a dry eye in the courtroom.
She told St. Charles County Judge, Michael Fagras, that her 15-year-old grandson still has nightmares about his father's death. Burch shook with emotion as she testified – and the podium shook with her.
She talked about her son and the impact the murder had on her and her grandson. Louis had suffered a traumatic brain injury during a car accident, which left him with the developmental capacity of a child. He worked in recent years caring for others with developmental disabilities.
He didn’t make a lot of money, but every Friday when he got his paycheck, he would take his son to Walmart to get a toy. When he was first murdered, that was the memory his then 11-year-old son clung to and told his grandmother he missed. The three of them lived together and now it’s just the two of them.
Her testimony was powerful. She spoke from the heart. She’s lived this, the love for her lost son, and what she’s done through the circus that Pam Hupp has put her through. She told the court that she did not want Hupp to profit from her son's murder. The Judge was gracious and kind – noting that she had never gotten to tell her story till that day and expressing sincere condolences. What a privilege to represent her and stand next to her through this.
Because Margaret came to me after the three-year statute of limitations had expired, we had to address it head on in our case. After research and analysis, we did it in two ways (and a third materialized later).
First, in our petition we alleged that Hupp was equitably estopped and was foreclosed, as a wrongdoer, from asserting a wrongful death statute of limitations defense in this case. State ex rel. Beisly v. Perigo, 469 S.W.3d 434 (Mo. banc 2015). In this case, the Missouri Supreme Court held:
This Court holds the application of common law maxims precluding one from benefiting from his or her own fraud and application of the doctrine of equitable estoppel bars Relator from asserting the statute of limitations as a defense to Irwin's cause of action.
In so doing, this Court follows the dictates of O'Grady by interweaving legislative policies with the inherited body of common law principles so as to reach a remedial purpose ensuring that tortfeasors be held liable for the consequences of their actions and cannot benefit from their own fraud.
This Court cannot fathom that the legislature's intent when enacting the wrongful death statute of limitations was to permit tortfeasors to evade liability for causing wrongful deaths so long as the tortfeasor could conceal their wrongdoing until the statute of limitations expired, while other tortfeasors, guilty of the same conduct, except for the fortuity that it merely caused injury instead of death, would be held liable for damages. Such a reading of section 537.100 would lead to an absurd and illogical result.
The circuit court did not abuse its discretion in overruling Relator's motion to dismiss Irwin's wrongful death suit because the doctrine of equitable estoppel forecloses Relator from relying on the statute of limitations as an affirmative defense due to his fraudulent concealment of his wrongdoing.
The court made specific findings regarding this case and the Statute of Limitations issues. Second, we alleged Assault and Battery – an intentional tort with a longer statute of limitations. This is also much harder to discharge in bankruptcy.
We also alleged Fraud and Misrepresentation – for lying about Louis murder to escape statute of limitations, claim preclusion and also to prevent bankruptcy discharge.
Third, Hupp never answered the lawsuit. Statute of limitations is an affirmative defense and not an element of an initial claim. For a defendant to assert it, they must file a Motion to Dismiss or Answer asserting that the statute of limitations has passed to bar the suit.
A party must plead all affirmative defenses, including a statute-of-limitations defense, and more specifically, the defending party must plead the very provision on which he depends in order to take advantage of a statute of limitations. Mo. Sup. Ct. R. 55.08. Scott v. King, 510 S.W.3d 887 (Mo.App. ED 2017).
Hope you continue to weather the Corona Pandemic well. Rather than talk about that I thought I would discuss two important auto insurance issues.
My friend, Tyson Mutrux, asked me to present with him for a couple of Continuing Legal Education classes at the Missouri Solo and Small Firm Conference. It will of course be virtual this year – August 19 - 21, 2020.
We are teaching other lawyers about: Maximize Your Client’s Un/Underinsured Motorist Claim During a Pandemic and Bad Faith claims.
So, I thought I would take a little bit of the content and share some aspects of underinsured and underinsured motorist claims. We recorded our presentations and will be moderating them. Should be good watching. I am psyched to see some of the other presentations too.
Uninsured and underinsured claims are against the client's own insurance company. Clients sometimes think that means they are easy or simple. NO – they are as easy and simple as 2020.
I try to answer insurance questions for free – so call me at [wdac-phone] if you have one.
All auto insurance policies carry a minimum uninsured motorist coverage in Missouri in the amount of $25,000.
If you, a family member or friend are injured in an automobile accident and the driver who was at fault did not have insurance, and is uninsured, your insurance pays. This includes compensation for medical expenses, wage loss, pain and suffering and emotional distress.
Every policyholder has this coverage and it is the same as if the other driver actually did have insurance – but your insurance policy provides coverage for the other driver’s negligence.
Uninsured coverage applies:
The answer to a question I often am asked is make an uninsured claim even if you are worried your premiums may go up. Some tips in making these claims:
Underinsured coverage is not mandatory in Missouri. It provides coverage if the first party (tortfeasor) defendant has less insurance than the damages suffered by the plaintiff.
To make an underinsured claim, first settle the claim with the tortfeasor and exhaust their coverage. Claimant has to get all the money available from the negligent driver. If the negligent driver has $25,000 in insurance, and settles that claim for $20,000 – the underinsured claim is gone.
Put underinsured carriers on notice, and let them know of the claim, let them know when the case against the tortfeasor driver settles, and make sure they do not object. Then, the claim is ripe against the underinsured carrier. Notice should be done in writing, and will assign a claim number.
It’s kind of crazy, but sometimes, insurance companies will not admit to underinsured coverage or tell a client how to make that claim. They will have separate claims adjusters and separate departments for underinsured coverage. The adjuster for a property damage or medical payment coverage will not tell a claimant they have a possible uninsured claim or a possible underinsured claim.
Adjusters can call asking if you are really trying to settle a property damage claim, or get medical payment coverage or what exactly I was writing about. They try to trick and create obstacles – even a lawyer like me. So, always make an underinsured claim clearly, in writing and ensure an underinsured claims adjustor is assigned -separate from any property or med pay adjustor.
Remember you cannot stack underinsured coverage. Also remember there is usually a set off amount recovered from underlying insurance – which raises issues that can make it difficult to determine the exact amount of coverage – see below.
A couple weeks ago we took a trip to Colorado to visit my brother. Traveling during the pandemic is weird. Drove there and back. One day each way and brought my parents. We had a great time bonding with each other. Making memories.
All meals were cooked in or carried out except one – ate outside away from folks for one meal. Masks and hand sanitizers all the way. It was a bit weird, but it’s becoming the new normal.
Crested Butte, Colorado is a magical place: beautiful mountains and amazing hiking and mountain biking. The kids only complained a little about the daily hikes. Takes a few days to get used to the altitude. Really cold in the winter – January is the coldest month with an average temperature of 11.8 °F. The average temperature for the whole year is 34.7 °F.
My son and I summited Mount Crested Butte at 12,168. Not a 14er but a good climb. It was fun horseback riding in the mountains, walking the Royal Gorge Bridge and whitewater rafting the Taylor River.
In Missouri the claimant can stack the minimum $25,000 uninsured from every vehicle owned under that same policy in that household.
This is because uninsured coverage is mandatory and the State of Missouri, both through statutes and court decisions, require that coverage.
For example, if you are injured and your vehicle has $25,000 of uninsured coverage, but also two other vehicles that are insured on that policy, you will have $75,000 in uninsured coverage.
Insurance companies will never tell you this and very often try to settle uninsured claims directly with their claimants without advising them.
Stacking is defined as an insured’s ability to obtain benefits either from more than one insurance policy, as when the insured has two or more separate vehicles under separate policies, or from multiple coverages within a single policy, as when an insured has one policy that covers more than one vehicle. Martin v. Auto Owners Insurance Company, 486 S.W.3d 390, 393 (Mo. App. W.D. 2016).
In Floyd-Tunnell v. Shelter Mut. Ins. Co., 439 S.W.3D 215 (Mo. banc 2014), Plaintiff’s husband was killed in an accident involving an uninsured motorist. Each of three auto policies in the household provided $100,000 UM coverage, but contained an “owned vehicle" exclusion which limited coverage to the mandatory minimum if the insured was injured while occupying a vehicle.
Defendant paid $100,000 on the vehicle involved in the accident, but only $25,000 under each of the other 2 policies based on the "owned vehicle" exclusion. The Supreme Court held that the term "insured" referred to the decedent, and not to the wife (who was not in the vehicle at the time of the accident).
The court believed the policy had to be viewed with the decedent as the "insured". The court held that the declarations page had to be read in conjunction with the policy language indicating that the declarations were subject to the conditions and exclusions contained in the policy.
Missouri law mandates that all policies of automobile insurance in this state must include uninsured motorist coverage. RSMo. § 379.203
Missouri public policy flowing from this statute requires that multiple uninsured motorist coverages must be allowed to be stacked, and prevents insurers from including policy language denying stacking.
Missouri Supreme Court has ruled underinsured motorist policies can set off amounts based on prior payments if the policy language allows such an offset – Owners Ins. Co. v. Craig, 514 S.W.3d 614 (Mo. banc 2017)
In Owners, the policyholder had an underinsured motorist policy with a $250,000 limit. She had already received a $50,000 policy-limit settlement from the at-fault motorist.
The parties stipulated that her damages exceeded $300,000, but the Supreme Court ruled Owners could offset the $50,000 received against the $250,000 policy limit, so it owed the policyholder $200,000, rather than the $250,000 underinsured motorist policy limit.
But remember Missouri Underinsured Motorist Statute – RSMo. § 379.204: “Any underinsured motor vehicle coverage with limits of liability less than two times the limits for bodily injury or death pursuant to § 303.020 shall be construed to provide coverage in excess of the liability coverage of any underinsured motor vehicle involved in the accident.”
The intent of § 379.204 is to prevent insurance companies from offsetting the entire amount of purported underinsured motorist coverage of $25,000.
Under § 379.204, any underinsured policies less than $50,000 (for example, a $25,000 UIM policy) will become excess over a $25,000 liability policy – therefore the injured party and underinsured policyholder will be able to recover $25,000 from the tortfeasor and then $25,000 in excess from their underinsured motorist policy, assuming their damages exceed $50,000.
And note that an insurance company can never promise on the declaration page to provide the consumer with a certain amount of underinsured motorist coverage and then take it away in the fine print of the multi-page insurance policy.
So, this week we again see my fellow Missouri lawyers Mark and Patricia McCloskey in the news at the Republican National Convention. Since they brandished their weapons on a BLM march in June, they have more than doubled down on their notoriety.
Below, I discuss in detail a lot more about insurance claims. My email from 8/4 discussed uninsured and underinsured coverage. I also discussed stacking of uninsured and set offs of underinsured.
Today I turn to Bad faith and vexatious refusal to settle claims. This arises from the talk I did at the Solo and Small Firm conference last week with my friend Tyson Mutrux.
I try to answer all insurance questions for free – so call me at [wdac-phone] if you have one.
And speaking of bad faith – "what about the McCloskeys?" I am asked that as a lawyer a bunch. I am sure all lawyers in the area are.
So, I discuss some stuff about what they have done – regardless of anyone's view of the propriety of their actions in the first place – everyone agrees you can protect your own home.
It's when an insurance company will not reasonably settle a claim and damages its insured, or customer, in Missouri.
Bad Faith is "the intentional disregard of the financial interest of Insured in the hope of Carrier escaping the responsibility imposed upon by its policy." Scottsdale Ins. Co. v. Addison Ins. Co., 448 S.W.3d 818, 828 (Mo. 2014)
It is well established that an insurer owes to its insured a duty to act in good faith in settling a claim against the insured and that the insurer may be liable to the insured when it breaches this duty.
An insurance company cannot gamble with the insured’s assets:
“[Carrier] is not permitted to take a gamble on getting a favorable verdict rather than to make a settlement within the limits of the policy.”
“[W]here [Carrier]'s and [I]nsured's interests’ conflict, [Carrier] cannot protect its own interests to the detriment of Insured's interests, but instead, the [Carrier] must sacrifice its interests in favor of [Insured]’s." Truck Ins. Exch. v. Prairie Framing, LLC, 162 S.W.3d 64, 95 (Mo. Ct. App. 2005)
Here are the legal elements:
The existence of bad faith is a question of fact to be determined on a case-by-case basis.
In situations where an insurer fails to inform the insured of settlement offers and the status of negotiations, the second requirement that the insured demand that the insurer settle the claim is not necessary to show bad faith.
“Bad faith is [a state of mind] indicated by the Carrier's acts and circumstances and can be proven by circumstantial and direct evidence.” Johnson v. Allstate Ins. Co., 262 S.W.3d 655, 662 (Mo. Ct. App. 2008)
My friend, Debbie Champion, and I did three great podcasts a bit ago on insurance coverage and bad faith. You can find them wherever you listen to podcasts.
Typical conduct showing bad faith:
The tort of bad faith failure to settle creates liability to compensate [I]nsured when [I]nsured has been wrongly subjected to an excess judgment and to deter [Carriers] from failing to fulfill fiduciary duties to their Insureds. Shobe v. Kelly, 279 S.W.3d 203, 279 (Mo. Ct. App. 2009)
Remember that “an insurer's ultimate settlement for its policy limits does not negate the insurer's earlier bad faith refusal to settle and that an excess judgment is not essential to a bad faith refusal to settle action” Scottsdale Ins. Co. v. Addison Ins. Co., 448 S.W.3d 818, 821 (2014).
Remember that you have to try and get a verdict over the policy limit in the underlying case in order for the insured to have a bad faith claim against the insurance company which they can then assign to you.
So how do you successfully ensure that you can prove bad faith? Well – hire me and I will do my best to make that happen. I cannot give away all my secrets in these emails. ;- ). There are many other issues such as 537.058 letters which enable you to get written demands into evidence in Bad faith trials.
But there are other issues too, like 537.065 agreements, reservations of rights, Hammer letters, documenting bad faith, duty to defend, interpretation of insurance policies. Etc. Rather than further getting in the weeds on this, give me a call at [wdac-phone] to discuss.
Is their portrayal honest or trying to get their 15 minutes of fame, stir up racial animus or feed into a portrayal of all protests as violent and threatening?
To borrow the bad faith definition above, are they showing intentional disregard of fair facts in the hope of escaping the responsibility imposed in them by their oath as lawyers or fundamental fairness? You can probably tell what I think. A lot of lawyers get asked about the McCloskeys. Can we bill them our time for answering? Class action? What about their neighbors?
I am all for protecting property, but this seems silly, contrived and conflated well beyond what occurred with political agendas. They live in the Central West End near the mayor (where the marchers were going) – not in some compound in Idaho.
Will they sue me for asking this? They have sued a lot of folks and seem like aggressive people – even to bees.
Does anyone want to keep seeing them or talk about this? Not me – back to insurance companies.
Vexatious refusal in Missouri are penalties against the injured person's insurance company and are thus different from bad faith. "Vexatious" means "without reasonable or probable cause or excuse."
Elements of a claim for vexatious refusal to pay:
See RSMo. § 375.296, § 375.420; Progressive Preferred Ins. Co. v. Reece, 498 S.W.3d 498 (Mo. Ct. App. W.D. 2016); Vantage Credit Union v. Chisholm, 447 S.W.3d 740 (Mo.Ct. App. E.D. 2014).
Common Grounds for an Action for Vexatious Refusal to Pay
So, what damages do you get for Vexatious?
Under § 375.420, 20% of the first $1,500 of the loss and 10% of the loss in excess of $1,500 together with reasonable attorney's fees, in addition to the amount of recovery owing under the policy.
Attorney fees can be assessed in a vexatious refusal to pay case even if the jury does not assess any penalty damages under the statute. DeWitt.
It is kind of funny that courts say the trial court is an expert on the value of legal services – however, a jury is not. See Howard Const. Co. v. Teddy Woods Const. Co., 817 S.W.2d 556 (Mo. Ct. App. W.D. 1991).
What if they pay the day before trial?
Answer: The fact that the insurance company pays, paid, or eventually pays all or part of the amount owing under the policy does not eliminate a claim under § 375.420.
The Supreme Court in Dhyne, in response to such an argument, stated:
Adopting State Farm's argument would permit an insurance company to refuse payment and avoid liability under § 375.420 by simply paying prior to trial. Such an interpretation would, from a practical standpoint, eliminate § 375.420.
Call me at [wdac-phone] if you have vexatious questions.
I thought I would talk a little today about Good Faith, as opposed to my theme in the last email. I can describe how to fight insurance companies acting badly, but sometimes, they act in good faith.
In law, the premise of good faith is that each party to a contract will make an effort which is honest in fact to meet terms and spirit of performance and enforcement obligations. A covenant of good faith and fair dealing is implied in all contractual relationships, including insurance agreements.
Below I talk about three settlements we obtained through zealous representation of our clients and in which the insurance companies acted in good faith. And when I say 'we' I should, in good faith, say Genavieve Perino and Tyler Thompson – two attorneys with whom I am lucky to work.
In the spirit of good faith, I also share some feedback from my comments about Mark and Patricia McCloskey at the Republican National Convention and share a new ad with them in it by the Lincoln Project.
Let me share a great dog rescue we are involved in – Home 2 Home. You can check out the “adoptables” album on the H2H Facebook page or the “adoptables” highlight on their Instagram page for more.
Injury claims involving concussions can be real wildcards, because oftentimes there is no objective evidence of injury, the treatment is sparse, the bills are low, and insurance adjusters disregard your client’s subjective complaints of memory loss and headaches.
However, at Burger Law, we know how to add value to these claims and persuade insurance companies to compensate concussions in good faith.
For example, Genavieve recently obtained a $50,000 policy limits settlement for her client Amanda who suffered a concussion in a car accident, and we are currently pursuing an underinsured claim as well.
It is crucially important for a concussion patient to be evaluated by a neurologist. Unlike a herniated disk or broken bone, concussions cannot be diagnosed through X-rays or MRIs. Insurance adjusters tend to discredit symptoms that are only based on what a patient says, such as memory loss or headaches. However, a neurologist will utilize specialized cognitive testing that leads to the best care for your client AND that will show the real legitimacy and harm from a concussion to an adjuster (or jury!).
Burger Law helped coordinate Amanda’s appointment with a neurologist, who diagnosed her with post-concussion syndrome caused by the car accident and then referred her to cognitive rehabilitation where she was treated for three months.
Concussion patients often assume that there is nothing that can be done to treat these injuries and don’t have any treatment or bills apart from the initial ER visit. However, Amanda’s cognitive rehabilitation, which involved speech pathology, eye muscle coordination, visual tracking, and other exercises, helped her recovery and added value to her case due to the documented treatment and medical bills.
The demand letter in these cases is also uniquely important. A concussion is a type of mild “traumatic brain injury.” The phrase “traumatic brain injury” tends to evoke more of a response from adjusters than just “concussion,” so this terminology was used in the letter.
Since the bills were not very high, Genavieve emphasized the severity of the injury in a way that is not captured in the records.
She described the difficulties Amanda experienced in detail, such as memory lapses, difficulties with word retrieval, critical thinking, and attention deficits, and illustrated how they interfered with her daily life as a school psychologist, graduate student, wife and mother.
The tragedies involving players with head injuries in the NFL have shed light on the severity of concussions that was previously ignored. Thus far, the NFL has already paid out nearly one billion dollars to eligible players and their families. With challenges to that settlement rejected.
If there is one thing insurance companies care about, it is their pocketbooks, so it doesn’t hurt to remind the adjuster of these figures. Burger Law knows how to maximize settlements in these tricky head injury cases.
On September 1, 2019, Daniel Dotson was driving south on Baxter Road at its intersection with Manchester Road in St. Louis County when Mr. Shanmugam ran a red light, crashing into Daniel’s vehicle. Daniel suffered serious injuries to his head, neck, back, shoulders, arm, knee, and foot. He suffered a concussion and a number of ligament tears, and had to undergo surgery to repair his shoulder.
We obtained Daniel’s medical records and bills and demanded $250,000 in settlement, which was the insurance policy coverage available. Mr. Shanmugam’s insurance company elected to act in good faith and paid the full $250,000 limit.
Daniel is very happy with the settlement and the services and aid our firm provided to him. Our recovery for Daniel will allow him to move forward with his recovery and he will have the financial resources to do so.
Much of the response to the McCloskey article I wrote two weeks ago was positive and thought I had good points. But, to act in good faith, I should report one comment from a friend who emailed me saying:
Gary, you forgot to mention the fact that a publicity hound of a prosecuting attorney filed bogus felony charges against them blowing the whole event out of proportion and back into the national news. (A prosecutor who fails to charge or drop charges in major felony cases). However, to mention this fact would not fit the scenario you want to paint.
Good point – I did have a scenario.
But I think that scenario is founded in fact and echoed in my newest favorite podcast: The Lincoln Project.
The Lincoln Project is now doing a commercial featuring the McCloskeys. Here's a description:
In the new minute-long commercial shared exclusively with Morning Consult, the group links Kyle Rittenhouse’s alleged Aug. 26 killing of two people at a Black Lives Matter demonstration in Kenosha, Wis., to Trump’s rhetoric and his elevation of Mark and Patricia McCloskey, who were awarded an Aug. 25 speaking slot at the Republican National Convention after brandishing firearms at demonstrators outside of their home in St. Louis on June 28.
Zachary Murray suffered injuries on October 9, 2019, when another driver abruptly changed lanes and swerved into his motorcycle’s lane of travel.
Zach was thrown from the vehicle and had abrasions running the length of his right side. He had serious injuries to his right shoulder, head, right knee, left wrist, left hand, and left arm.
We demanded the $250,000 insurance policy limit for Zach and the company paid the full $250,000 available in coverage – good faith abounds this week.
Zachary is very happy to have the financial resources necessary to aid him in his recovery.
It’s fall and that means harvest time. I harvested my honey last week. Really happy to have a bigger yield than last year. And I learned a lot as well. Observing the bees to learn about their behavior and the lessons they teach has been a great experience. It can be humbling to have a hobby with so much to learn and appreciate how nature will always throw us curve balls. Life lessons perhaps.
This was a good year for bees in terms of honey flow. This is the second good year in a row in our area. This comes from good nectar flow from flowers and water in the early part of the year.
But bees are still facing many challenges in America and around the world. They suffer habitat loss and fragmentation, disease from the Varroa destructor mite, pesticides and climate change.
Below I discuss a couple settlements and my weekly Ask a Lawyer FB live show on Wednesdays. And although this email comes on the heels of the terrible loss of Justice Ruth Bader Ginsberg, I frankly cannot bring myself to write about that. It’s a profound loss with such enormous consequences for the Supreme Court and rights I and millions of Americans hold dear, that I cannot do it justice now. Others have done so very well.
Although, to briefly paraphrase Shakespeare in Romeo and Juliet: Death, that hath suck'd the honey of thy breath, hath had no power upon thy words, strength or notoriety.
So back to beekeeping – when we take honey from bees, we take only extra honey they make and not what they need for winter. Yes – bees make honey in abundant spring and summer months to have food for winter. And we make sure they are good for the winter months.
To get the honey, I remove boxes that were on top of the hives, but leave the bottom boxes – which contain honey, and the egg laying, or brood development area. They get a little mad when their honey is taken.
The next day we went to the bee store and brought my little one with us. We got him a little beekeepers’ outfit. When we got home, he put it on and wanted to go to the hives. He had no fear and enjoyed getting really up close.
We were able to get a solid result for Michelle's daughter recently. They experienced a parent’s nightmare – a broken bone at a birthday party.
The claim was against a local gymnastics place that promotes parties. They had a lot of kids and only one person supervising a balance beam activity. No one spotted her daughter, who fell a relatively small distance but broke her leg.
She had surgery and thankfully had a really great recovery. You'd think the defendant and its insurance company would take care of this little girl. But no – they fought us really hard.
First, they tried to get Michelle to sign the waiver the day after the incident to avoid any responsibility. She would not. Remember, waivers can be enforced to obviate liability but only when the insured can come up with a signed waiver. Don't sign one after an incident. Then they said they had a witness statement saying they had adequate staff and it was the girl’s fault. We came up with witnesses proving that position a lie.
Lastly, they low balled us and would not pay. So, as usual, we filed suit and pushed the case. We were able to settle shortly after filing. We filed a motion for approval of the settlement and put the entire amount in a structured settlement to help in the future.
I get asked all the time whether a prospective client needs a lawyer in such a cut and dry case. I often explain how a year or two later after a fight that same client really appreciates that they hired me.
I continue to do a Facebook live show each Wednesday at 3 p.m. We have had some really great guests the last few weeks – all friends who graciously answered questions in their areas.
Last week I discussed a wide array of topics with criminal defense lawyer Eric Abramson. And the week before Nedim Ramic discussed his personal injury practice and the St. Louis Bosnian community.
Our client Peyton suffered serious injury on February 22, 2020, when riding in a vehicle driven by Hailey Cook. Ms. Cook veered off the road and crashed into a dirt pile head-on.
Peyton had to be air-evacuated from the accident site and required significant treatment.
Unfortunately, only $100,000 in insurance coverage was available but we were able to quickly secure the policy limit for Peyton, allowing him to use the settlement money for his treatment and recovery.
We were able to use the Missouri Lien statute to lower his bills and make sure the bill collectors do not follow him around. In cases where the damages exceed the insurance coverage, we make sure we fight hard to lower the liens as much as possible.
Peyton and his family are happy with the settlement and our firm’s ability to provide fast assistance.
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