Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

The Eighth Circuit reversed the district court's grant of summary judgment for American Family in an action brought by plaintiff seeking uninsured motorist coverage from American Family after he was involved in a car accident. The court held that material facts remained unresolved regarding the proximate cause of the accident. In this case, a question of fact exists regarding whether the other driver's entry into the highway, alone, caused the accident or whether the brown car's entry ahead of the other driver caused him to stop, making the accident unavoidable. View "Cottrell v. American Family Mutual Insurance Co." on Justia Law

The Eighth Circuit affirmed the district court's orders requiring it to deposit $21 million in disputed insurance proceeds to maintain its federal statutory interpleader claim and dismissing Ronald Gean and the Estate of Jean Carol Gean for lack of personal jurisdiction in its declaratory judgment claims. The Geans are citizens of Michigan and were injured in an automobile accident in Illinois by a truck operated by Rex, a Missouri company.The court agreed with the district court that subject matter jurisdiction was lacking because Acuity did not deposit the disputed amount into the court's registry. The court rejected Acuity's argument that the district court had personal jurisdiction over the Geans. Rather, the court held that the district court lacked personal jurisdiction over the Geans in the remaining declaratory judgment action. View "Acuity v. Rex, LLC" on Justia Law

The Eighth Circuit affirmed the district court's judgment in an insurance coverage dispute over the allocation of a $6 million settlement in an underlying product liability action. The court held that the district court did not err in interpreting the Batch Clause Endorsement and its construction of the term "lot." The court rejected Federal's arguments to the contrary and affirmed the district court's ruling that AIG be paid $500,000 by Donaldson and be reimbursed over $2.76 million by Federal. View "National Union Fire Insurance Co. of Pittsburgh v. Federal Insurance Co." on Justia Law

The Eighth Circuit agreed with American Family that the district court erred in holding that the matching exclusion did not apply to the insureds' policy. Reviewing the district court's interpretation of the insurance policy de novo and applying Minnesota law, the court held that even if it were to discount the matching exclusion's explicit statement that it modifies the Form, as the district court did, other circumstances unambiguously showed that the Minnesota Endorsement, and thus the matching exclusion, applied to the insureds' policy. Therefore, the district court erred in reading the matching exclusion in the policy and, after applying the explicit and unambiguous exclusion, American Family was not obligated to pay for damages attributable to matching difficulties. View "Noonan v. American Family Mutual Insurance Co." on Justia Law

After Jeffrey Odom died in a motor vehicle accident driving a pick-up truck owned by his employer and insured by Berkley, Odom's widow filed a claim with Berkley for underinsured motorist (UIM) benefits. Berkeley then filed a diversity action seeking a declaratory judgment of no UIM coverage and plaintiff counter-claimed. The Eighth Circuit affirmed the district court's grant of Berkley's motion for summary judgment and held that the other driver's vehicle was not an "underinsured motor vehicle" as defined in Berkley's policy and in the auto insurance provisions of the North Dakota Century Code. View "Berkley Regional Insurance Co. v. Bernick-Odom" on Justia Law

After a fire seriously damaged the insureds' home, the insurer paid for their total property damage and then brought a diversity action against Entergy, alleging that the utility's equipment caused the fire. The insurer alleged subrogation claims for damages in excess of the amount paid for the damage.Although the district court erred in determining that the insurer did not have standing, the Eighth Circuit affirmed the district court's grant of Entergy's motion for judgment as a matter of law because the insurer failed to prove that the insureds were made whole either before or during this lawsuit. Therefore, a reasonable jury could not have found that the insurer proved an essential element of its subrogation claim. View "EMC Insurance v. Entergy Arkansas" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for LM General in an uninsured motorists (UM) coverage dispute. The district court concluded that there was no UM coverage because any liability of the uninsured motorist and his occupants to plaintiff did not arise out of the use of the uninsured motor vehicle.The court held that Missouri law requires UM coverage whenever an uninsured motorist is liable for injury to the insured arising out of the motorist's use of his uninsured auto. In this case, the injuries inflicted on a victim of a drive-by shooting by the occupant of a motor vehicle were not injuries which arise out of the "use" of the motor vehicle because the motor vehicle was merely the "situs" or "locus" of the cause of the victim's injuries and the discharge of the gun was unconnected to the inherent use of the motor vehicle. View "Patel v. LM General Insurance Co." on Justia Law

Restaurant Recycling filed suit against Employer Mutual, seeking a declaratory judgment that the insurer had a duty to defend and indemnify Restaurant Recycling. Restaurant Recycling was seeking a declaratory judgment and indemnity from an underlying lawsuit alleging that the company delivered defective shipments of recycled fat in which New Fashion Pork used as an ingredient in its swine feed. The court held that the total pollution exclusion in the insurance policy limited coverage in this case because the damage arose from dispersal of lasalocid, which Restaurant Recycling conceded was a pollutant. View "Restaurant Recycling, LLC v. Employer Mutual Casualty Co." on Justia Law

The parties agreed that the anti-stacking provision barred the insureds from recovering any money from Country Preferred for a car accident. The insureds contend that as a result, Country Preferred committed fraud and was unjustly enriched by collecting three separate premiums for underinsured motorist (UIM) coverage, when the anti-stacking provision rendered the UIM coverage in the insureds' second and third policies worthless or "illusory" under Missouri courts.The Eighth Circuit affirmed the district court's dismissal of the fraudulent misrepresentation and unjust enrichment counterclaims, holding that the anti-stacking provisions did not render UIM coverage in multiple policies illusory because the premium paid for coverage under each policy corresponded with an increase in coverage. In this case, payment for UIM coverage under the insureds' second and third insurance policies buys coverage for non-named, non-family passengers and drivers of the insureds' second and third vehicles. View "Country Preferred Insurance Co. v. Lee" on Justia Law

The Eighth Circuit affirmed the district court's order finding that Prudential did not abuse its discretion when it terminated plaintiff's long term disability benefits. The court held that, although plaintiff presented some evidence that he was disabled, Prudential's decision to deny benefits was supported by substantial evidence. In this case, Prudential had evidence that plaintiff was deliberately exaggerating his symptoms, making it impossible to determine whether he had cognitive deficiencies that rendered him disabled. View "Johnston v. Prudential Insurance Co." on Justia Law