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

This declaratory judgment action concerned a controversy over the limits of an insurance policy issued by Insurer to Insured. A livestock company (Company) brought suit in Minnesota state court against Insured after Company's cattle in Insured's care died in unusually high numbers. Insured submitted the complaint in the underlying action to Insurer. Insurer refused to defend or indemnify Insured in the case brought by Company, basing its denial of coverage on an exclusion in the liability insurance policy for damage to property in the "care, custody, or control" of the insured. The Minnesota district court entered judgment against Insured. Insurer then commenced this action against Company and Insured in federal district court, seeking a declaratory judgment that the claims alleged in the underlying action were not covered under Insured's policy with Insurer and that Insurer therefore had no obligation to defend or indemnify Insured. The district court concluded that the claims were covered by the policy and granted Company and Insured's motion for summary judgment. The Eighth Circuit Court of Appeals reversed, holding that because Company's cattle were under Insured's care, custody, and control when they were damaged, the policy did not provide coverage for Company's claimed loss. Remanded.

Jason McCann was involved in an automobile accident with Jeffrey Kreml. McCann's insurer, Auto Club Insurance Association, defended McCann against Kreml's personal injury action. After Kreml and McCann settled, Auto Club sought contribution from Sentry Insurance, the insurer for McCann's employer, claiming Sentry was obligated to provide co-primary coverage for McCann. The court granted summary judgment to Sentry, finding the Sentry policy only obligated Sentry to provide excess liability coverage, and McCann had no excess exposure because he settled within the limits of the Auto Club policy. The Eighth Circuit Court of Appeals affirmed, holding that the district court's interpretation of the policy was reasonable.

Sandra Emas owned a life insurance policy issued by ReliaStar. The policy named her estate as the beneficiary. When Emas died intestate, she left her son, Jaysen McCleary, as her only heir. McCleary was appointed the administrator of his mother's estate. McCleary later filed for personal bankruptcy. McCleary, as the administrator of the estate, subsequently filed suit against ReliaStar, alleging that ReliaStar had wrongfully refused to pay the estate benefits under Emas's insurance policy. ReliaStar moved for summary judgment, arguing that Emas's interest in any cause of action against ReliaStar passed immediately to McCleary upon her death. The district court granted summary judgment in favor of ReliaStar. The Eighth Circuit Court of Appeals affirmed, holding (1) the estate was functionally closed, and McCleary could not bring a suit on behalf of a closed estate; and (2) there was not an issue of fact as to whether McCleary sold the estate's interest in his bankruptcy proceedings, as McCleary had the authority to sell the estate's interest in its claims against ReliaStar.

Appellants appealed from the district court's grant of summary judgment in favor of American Standard. The district court concluded that appellants were not entitled to recover underinsured motorist (UIM) coverage benefits under four American Standard policies because the tortfeasor's vehicle was not an "underinsured motor vehicle" under the policies' plain language. The court held that the district court correctly concluded that appellants were not entitled to recover under the UIM policies because stacking them did not result in an amount exceeding the tortfeasor's liability. Accordingly, the court affirmed the judgment.

LINA appealed the district court's ruling that LINA abused its discretion in denying death benefits to Dawn McClelland based upon her husband's life insurance policy. LINA also appealed the district court's award of attorney's fees. The court found that LINA committed an abuse of discretion in denying benefits because its interpretation was contrary to the language of the plan that it would cover "loss of life" based upon an "accident" and because substantial evidence did not support its decision. The court also found that the total fee awarded should be $85,000 and remanded to the district court to enter an award in that amount. The prejudgment interest award was affirmed.

After plaintiff was denied long-term disability benefits by Standard, he sought review of Standard's determination under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The court affirmed the district court's grant of summary judgment in favor of Standard and held that there was substantial evidence supporting Standard's denial of benefits. The court also held that a conflict of interest alone was not determinative where there existed substantial evidence on the record supporting the denial of benefits.

Plaintiff sued Hartford seeking coverage under his life insurance policy for accidental dismemberment benefits after he suffered serious injuries to his eyes when a can of oven cleaner exploded in his face. The district court dismissed plaintiff's suit, concluding it was untimely because it was brought three years after the loss, outside the policy's time limitations for bringing legal actions against Hartford. Plaintiff appealed, arguing that he brought suit within Arkansas's five-year statute of limitations for breach of contract actions, Ark. Code Ann. 23-79-202(b). The court agreed with plaintiff and held that prior case law was inconsistent with Hartford's contention that the "period prescribed by law" referred to in section 23-79-202 meant something other than the full five-year period set forth in Ark. Code Ann. 16-56-111. Accordingly, the court reversed and remanded.

This appeal arose from an insurance coverage dispute where the City sought coverage from Genesis for 42 U.S.C. 1983 claims in the nature of malicious prosecution. Genesis filed suit against the City, seeking a declaratory judgment that its policies provided no coverage for the underlying actions. The district court granted summary judgment to Genesis and the City appealed, arguing that the district court erred in ruling as a matter of law that the policies did not provide the City insurance coverage for the claims. Because Genesis did not have an insurance contract with the City in 1977, when the underlying charges were filed, it did not have a duty to defendant and indemnify the city in the suits. Accordingly, the court affirmed the judgment.

Plaintiff sued Jessica J. Wright and her insurers for equitable garnishment to collect a state court judgment. Wright had hacked into plaintiff's voicemail and Facebook services, sending disparaging letters and emails about him, and making anonymous phone calls and texts to harass or defame him, among other things. The district court granted summary judgment to the insurers and plaintiff appealed. The court concluded that the Umbrella Policy covered personal injury arising from defamation or privacy violations and excluded coverage for personal injury arising from mental abuse. Therefore, the acts in this case - whether they were the results of Wright's negligence - were mental abuse and not covered by the insurance policy.

Plaintiffs sued defendants, seeking indemnification and reformation of a workers' compensation insurance policy. The district court granted summary judgment to defendants. The court concluded that Cascades' gratuitous assignment to Newton was valid under Minnesota law. Newton, as Cascades' assignee, was entitled to enforce both the right to indemnification and the right to reformation. He was a real party in interest, destroying diversity jurisdiction. Therefore, the court held that because the district court lacked subject matter jurisdiction, the court vacated and remanded.