State Farm Mutual Automobile Ins. Co. v. Bajah CA2/5

I. BACKGROUND

On January 27, 2019, Bajah failed to stop his automobile at a red light and collided with another vehicle driven by Wayne Muramatsu (Muramatsu). The collision, which occurred at the intersection of Venice Boulevard and Hill Street in Los Angeles, rendered Muramatsu’s vehicle a total loss. State Farm, Muramatsu’s insurer, investigated his claim, determined it was covered under the terms of his policy, and paid him $31,399.13 for his loss. Nine months later, in September 2019, after engaging in unsuccessful settlement discussions with Bajah’s insurer, State Farm sued Bajah seeking subrogation. Information collected at the time of the accident indicated Bajah resided in the City of Torrance. In an effort to find Bajah’s current residence, State Farm searched unsuccessfully for his address on the Internet using his social security number and telephone numbers. When a postal search indicated Bajah had “moved” from his Torrance address, State Farm investigated further using “skip-tracing” techniques and discovered two other possible residences for Bajah: one in the City of Hawthorne and one in the City of Castaic. On 21 occasions between September 2019 and February 2020,…