Justia Insurance Law Opinion Summaries

Articles Posted in Iowa Supreme Court
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An SUV was being driven in the wrong direction on a highway when it collided with a semi-tractor-trailer. The SUV was totaled, and the SUV’s driver was killed. Second later, a motorcyclist ran into the SUV that was still in the middle of the highway. The drivers of both the semi and the motorcycle suffered injuries. The drivers jointly filed a petition for declaratory judgment against the insurer of the SUV asking the district court to declare that there had been two accidents for purposes of the insurance policy’s per-accident limit on bodily injury liability. The district court granted summary judgment for the insurer, concluding that the injuries suffered by the plaintiffs arose from one accident. The Supreme Court affirmed, holding that, under the terms of the SUV driver’s insurance policy, there was only one accident. View "Hughes v. Farmers Auto. Ins. Ass’n" on Justia Law

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An SUV was being driven in the wrong direction on a highway when it collided with a semi-tractor-trailer. The SUV was totaled, and the SUV’s driver was killed. Second later, a motorcyclist ran into the SUV that was still in the middle of the highway. The drivers of both the semi and the motorcycle suffered injuries. The drivers jointly filed a petition for declaratory judgment against the insurer of the SUV asking the district court to declare that there had been two accidents for purposes of the insurance policy’s per-accident limit on bodily injury liability. The district court granted summary judgment for the insurer, concluding that the injuries suffered by the plaintiffs arose from one accident. The Supreme Court affirmed, holding that, under the terms of the SUV driver’s insurance policy, there was only one accident. View "Hughes v. Farmers Auto. Ins. Ass’n" on Justia Law

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The Iowa Individual Health Benefit Reinsurance Association (“IIHBRA”), a nonprofit corporation, sued its members (“the universities”) for unpaid assessments it was statutorily obligated to collect. The universities filed a motion to dismiss the petition, arguing that the IIHBRA lacks the capacity to sue based on the 2001 amendment to Iowa Code chapter 513C. Chapter 513C initially included a provision stating that IIHBRA had the power to “sue or be sued,” but the 2001 amendment deleted that provision. Alternatively, the universities argued that the district court lacked subject matter jurisdiction because the IIHBRA is required to arbitrate under Iowa Code 679A.19. The district court granted the motion to dismiss. The Supreme Court reversed, holding (1) the 2001 amendment to chapter 513C left intact the IIHBRA’s capacity to sue under Iowa Code chapter 504A; (2) the IIHBRA is not subject to mandatory arbitration under Iowa Code 679A.19; and (3) therefore, the IIHBRA has the capacity to sue its members in district court for unpaid assessments. View "Iowa Individual Health Benefit Reinsurance Ass’n v. Stat Univ. of Iowa" on Justia Law

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Dennis Hagenow was injured in an automobile accident with Betty Schmidt. Hagenow and his wife (Plaintiffs) filed an uninsured motorist claim with American Family Mutual Insurance Company. American Family denied the claim, determining that Schmidt’s vehicle was not an uninsured motor vehicle under Plaintiffs’ policy. Plaintiffs subsequently filed a breach of contract action against American Family. American Family moved for summary judgment, arguing (1) because Schmidt had automobile insurance at the time of the collision, she was not an uninsured motorist (UM) under the policy; and (2) Plaintiffs were not “legally entitled to recover” under the policy because a jury in Plaintiffs’ underlying action against Schmidt found Schmidt not liable for Plaintiffs’ damages. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiffs were not “legally entitled to recover” under Iowa law or their UM policy; and (2) Schmidt’s vehicle was not an uninsured motor vehicle under the terms of Plaintiffs’ UM provision. Remanded. View "Hagenow v. Am. Family Mut. Ins. Co." on Justia Law

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Plaintiff formed a contract with Imperial Premium Finance with regard to a financing arrangement for life insurance. Imperial later assigned its interest in the arrangement to Defendant, a limited partnership with its principal place of business in California. Plaintiff filed a petition for declaratory judgment in Iowa, claiming that the contract was not valid. The district court granted Defendant’s motion to dismiss for lack of personal jurisdiction, concluding that that contacts of Imperial, the assignor, did not impute to Defendant, the assignee. The Supreme Court reversed, holding (1) an assignor’s contacts with Iowa are not automatically imputed to the assignee for purposes of obtaining personal jurisdiction over the assignee, but this assignee is subject to personal jurisdiction in Iowa based on its own contacts with this forum through the contractual relationships it assumed by the assignment; and (2) Defendant in this case did have the required minimum contacts to subject Defendant to personal jurisdiction in Iowa. Remanded. View "Ostrem v. PrideCo Secure Loan Fund, LP" on Justia Law

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Plaintiff was a passenger who was injured while riding in the vehicle of his brother, who had coverage, including underinsured motorist (UIM) coverage, with Defendant. The policy contained a provision limiting the time to file an action to recover UIM benefits. Plaintiff brought this action to recover UIM benefits approximately one month after the deadline set forth in the policy. Defendant moved for summary judgment, claiming Plaintiff’s petition was untimely because he failed to file it within the policy’s two-year deadline. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiff, as an insured and a third-party beneficiary of the policy, did not have greater rights than the policyholder, and therefore, Plaintiff could not avoid the contractual time limitation unless the policyholder under similar circumstances would have been able to avoid it; and (2) the record did not demonstrate either that the policy’s time limit was unreasonable or that Defendant should be equitably estopped from enforcing it. Remanded for entry of summary judgment in favor of Defendant. View "Osmic v. Nationwide Agribusiness Ins. Co." on Justia Law

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Douglas Moad was driving his truck within the course of his employment with Employer when his truck was struck by an oncoming vehicle. Douglas died from his injuries. Employer maintained workers' compensation services with Dakota Truck Underwriters (DTU), a South Dakota corporation with its principal place of business in South Dakota. Employer also maintained motorist liability coverage with Northland Insurance Company (Northland). Douglas and his wife Sharon maintained insurance coverage with Property and Casualty Insurance Company of Hartford (Hartford). Sharon filed a petition seeking damages from Northland and Hartford for uninsured motorist benefits. DTU filed a notice of subrogation lien, asserting that it was entitled to reimbursement from any proceeds obtained by Sharon as a result of the damages action. Sharon reached a settlement agreement with Northland and Hartford. The district court approved the settlement and granted Sharon's motion to extinguish DTU's lien, concluding that in the event DTU's untimely filing of notice of its lien did not bar its interest, Iowa law applied and barred DTU's recovery. The Supreme Court reversed, holding that the district court utilized the wrong standard in resolving the conflict of laws question. View "Moad v. Dakota Truck Underwriters, Risk Admin. Servs., Inc." on Justia Law

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At issue in this case was whether the Iowa Insurance Commissioner's interpretation of a recently enacted law governing dental insurance plans should be upheld. Petitioner, the Iowa Dental Association (IDA), filed with the Insurance Division a request for a declaratory order clarifying the meaning of "covered services" in the statute. The Commissioner issued a declaratory order stating that an insurer may limit the maximum fees charged by dentists for services that a generally included in the insurer's dental plan, even though they are not actually reimbursed by the insurer because of a plan restriction. The district court affirmed the Commissioner's declaratory ruling. The Supreme Court reversed, holding that the services in question did not meet the statutory definition of "covered services" because they had not been reimbursed under the dental plan. Accordingly, an insurer may only impose a maximum fee on a service when a reimbursement has been provided for that service. Remanded. View "Iowa Dental Ass'n v. Iowa Ins. Div." on Justia Law

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A husband and wife applied for life insurance policies from Farm Bureau Life Insurance Company and later sued Farm Bureau for its alleged negligence in failing to notify them of their HIV-positive status. Farm Bureau settled the negligence claims, sued its insurers for indemnity, and sued its insurance broker for breach of contract and negligence in failing to provide timely notice to the insurers. The district court granted summary judgment (1) in favor of the insurers on the ground that Farm Bureau had failed to give them timely notice of the applicants' liability claims, and (2) in favor of the broker after concluding that even if the insurers had been given timely notice of the applicants' tort claims against Farm Bureau, coverage for those claims would have been precluded under two separate exclusions. In this appeal, Farm Bureau challenged the judgment in favor of the broker. The Supreme Court affirmed, holding that the underwriting exclusion would have precluded coverage for the applicants' claims even if the insurers had been timely notified under the policy's notice requirement. View "Farm Bureau Life Ins. Co. v. Holmes Murphy & Assocs., Inc." on Justia Law

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Chartis Insurance issued two workers' compensation insurance policies to Action Warehouse Company. Action, in turn, contracted with two tire companies to provide employees to operate tire warehouses owned by the companies and used exclusively to store the goods manufactured by the respective employers. Originally, Chartis classified the Action employees who staffed the warehouses under the National Council on Compensation Insurance (NCCI) classification code applicable to general warehouse employees. Later, Chartis retroactively and prospectively changed the employees' classification code to the code applicable to rubber tire manufacturing, resulting in a significantly higher premium. Action appealed. The NCCI Iowa workers' compensation appeals board ruled in favor of Chartis. The Iowa Insurance Commissioner reversed, and the district court affirmed. At issue before the Supreme Court was whether the Commissioner had the authority under Iowa Code 515A.1 to consider an as-applied challenge to a workers' compensation liability insurance rating schedule approved for use in accordance with Iowa law. The Supreme Court reversed, holding that the Commissioner did not have the authority to determine that a specific application of a plan approved under Iowa Code 515A.4 violated the statute's general purpose as outlined in section 515A.1 by being excessive, inadequate, or unfairly discriminatory. View "Chartis Ins. v. Iowa Ins. Comm'r" on Justia Law