Donald Gaddy et al. v. State Farm Fire and Casualty Company

Summary

The United States District Court for the Northern District of Oklahoma grants State Farm’s partial motion to dismiss the plaintiffs’ breach of contract claim. The court holds that the claim was filed outside the policy’s one-year suit limitation period and that the plaintiffs did not allege sufficient facts to establish waiver or equitable tolling. The plaintiffs’ bad faith claim was not subject to the motion and remains undismissed.

Holdings

1. The plaintiffs' breach-of-contract claim was time-barred because the policy required suit within one year after the date of loss, the alleged date of loss was June 17, 2023, and the action was not filed until June 12, 2025.
2. The plaintiffs did not allege sufficient facts to establish waiver or equitable tolling of the one-year limitations period.
3. The court could resolve the contractual limitations issue on a Rule 12(b)(6) motion because the dates alleged in the amended complaint made clear that the claim had been extinguished and no sufficient basis for tolling or waiver was pleaded.

Questions Presented

1. Whether the plaintiffs' breach-of-contract claim was barred by the policy provision requiring any action to be filed within one year after the date of loss.
2. Whether the plaintiffs alleged sufficient facts to support waiver or equitable tolling of the contractual one-year limitations period.
3. Whether the limitations issue could be resolved on a Rule 12(b)(6) motion based on the dates alleged in the amended complaint and the policy incorporated by reference.

Disposition

dismissed