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

Starr Indemnity filed suit seeking a determination of their rights and obligations under Continental Cement's insurance policies after the Mark Twain, a cement barge owned by Continental Cement, sank in the Mississippi River. Continental Cement counterclaimed for breach of contract and vexatious refusal to pay under Missouri law. Determining that Continental Cement did not waive its appeal, the court concluded that the district court did not err by applying the federal doctrine of utmost good faith, a judicially established federal admiralty rule, instead of Missouri state law; Continental Cement waived its appeal of the denial of its motion for judgment as a matter of law on Starr Indemnity's utmost good faith defense; and, apart from the issue of waiver, the district court did not abuse its discretion in submitting the utmost good faith instruction. Accordingly, the court affirmed the judgment of the district court. View "New York Marine & General Ins., et al. v. Continental Cement Co., et al." on Justia Law

Plaintiffs filed suit to recover losses sustained after a fire damaged their home. On appeal, plaintiffs challenged the district court's grant of summary judgment to Allstate. Plaintiffs claimed that the jury instructions misstated Missouri law and the elements of the claims and defenses. The court concluded that the jury instruction was not obviously erroneous and that any imprecision in this instruction was not the sort of egregious error that might warrant relief on plain error review in a civil case. Accordingly, the court affirmed the judgment of the district court. View "Young, et al. v. Allstate Ins. Co." on Justia Law

Baum filed suit against Twin City, its insurer, over a dispute regarding coverage of an IRS investigation. Reviewing the choice of law question in light of sections 188 and 187 of the Restatement (Second) of Conflict of Laws, the court predicted that the Missouri Supreme Court would apply New York law to this dispute; the court concluded that the policy provided coverage where Twin City's insurance agreement was ambiguous regarding any timely notice requirement applicable to later liabilities arising from a timely original claim; although the district court erred by applying Missouri law, the court affirmed the judgment of the district court; and the court affirmed the district court's declaration that a $3 million self-insured retention applied to the derivatives litigation because the litigation was sufficiently related to Baum's business underwriting and selling municipal bonds. View "George K. Baum & Co. v. Twin City Fire Ins. Co." on Justia Law

After two boys drowned at a pool party sponsored by the FCA, the boys' survivors filed suit against the FCA in state court, alleging negligence and loss of consortium. The FCA then filed this declaratory judgment and breach of contract action against its insurers in federal district court seeking a "judicial determination as to whether Iowa Claims constitute one or two occurrences" under its commercial general liability insurance policy. The court affirmed the district court's grant of summary judgment in favor of the primary insurer, holding that there existed only one occurrence. View "Fellowship of Christian Athletes v. Ironshore Specialty Ins." on Justia Law

Plaintiff sought coverage from Farm Bureau for flood damage to her home but failed to submit the one-page proof of loss form required by the federal standard flood insurance policy. The court concluded that plaintiff's failure to complete and submit the form precluded coverage as a matter of federal statutory, regulatory, and common law. Accordingly, the court reversed and remanded for entry of judgment in favor of Farm Bureau. The court declined to tax Farm Bureau's costs against plaintiff. View "Stoner v. Southern Farm Bureau Casualty Ins." on Justia Law

After the denial of his flood insurance claim, plaintiff filed suit against Farm Bureau alleging a state bad faith claim and federal breach of contract. The court held that the district court committed reversible legal error by excusing plaintiff from complying with the standard flood insurance policy's (SFIP) proof of loss requirement. Even if Farm Bureau wished to waive the proof of loss, FEMA has not authorized waiver in this case. Accordingly, the court reversed and remanded for entry of judgment in favor of Farm Bureau. View "McCarty v. Southern Farm Bureau Casualty Ins. Co." on Justia Law

United Fire sought a declaratory judgment that an insurance policy it issued to Rose did not provide coverage to Wayne Rockett, a supervisory level employee of Rose. The court affirmed the district court's grant of summary judgment to United Fire, concluding that the term "directors" in the insurance policy unambiguously provided coverage only to Rose's actual board of directors and not to employees such as Rockett. View "United Fire & Casualty Ins. Co. v. Thompson" on Justia Law

Plaintiff filed suit against his former employer, Annett, alleging that the company acted in bad faith when it failed to provide medical care and refused to pay him healing-period benefits. Annett counter-claimed for fraud. The court concluded that the district court correctly ruled that plaintiff was required to exhaust his claim with the commissioner; under Iowa law, Annett had a reasonable basis to believe that it could request plaintiff to undergo an examination by the company's chosen physician and plaintiff's refusal to submit to the examination made the propriety of the company's denial of healing-period benefits at least fairly debatable; therefore, the district court properly granted summary judgment for Annett on plaintiff's bad-faith failure to pay benefits claim; and, under either Iowa law or federal law, Annett was judicially estopped from proceeding against plaintiff because Annett had admitted liability in plaintiff's alternate care petition. Accordingly, the court affirmed the judgment of the district court. Annett's motion to strike portions of plaintiff's supplemental appendix was denied as moot. View "Spencer v. Annett Holdings, Inc." on Justia Law

Defendant appealed the district court's grant of Allstate's motion for summary judgment and denial of defendant's motion for summary judgment, concluding that defendant's son-in-law was not an insured person under an umbrella insurance policy. Because the plain language of the Allstate umbrella policy provided XL coverage only for the legal obligation of insured persons, and the son-in-law was not an insured person under the umbrella policy, the court affirmed the judgment of the district court. View "Allstate Indemnity Co. v. Rice" on Justia Law

United filed a declaratory judgment action against Titan, seeking a declaration that United did not owe a duty to defend or indemnify Titan against a pending state-court lawsuit because the policy's absolute pollution exclusion barred coverage for the claims raised in the lawsuit. Titan counter-claimed for relief. The district court granted Titan's motion and denied United's, entering a judgment declaring that United owed a duty to defend and indemnify Titan against the state-court lawsuit. The court concluded that an ordinary person of average understanding purchasing the policy would consider TIAH, an acrylic concrete sealant, to fall unambiguously within the policy's definition of "pollutant." Because the district court premised its denial of United's motion for summary judgment exclusively on the erroneous conclusion that TIAH does not constitute a pollutant, the court vacated the district court's order. The court declined to direct the entry of summary judgment in favor of United. The court remanded for further proceedings. View "United Fire & Casualty Co. v. Titan Contractors Service, Inc." on Justia Law