Justia Insurance Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Wesser v. State Farm Fire & Casualty Co.
The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court that Insured was not entitled to preaward interest from Insurer on an appraisal award based on Minn. Stat. 549.09, holding that the policy language limited interest on a loss to amounts accruing after an appraisal award is issued.After a fire damaged his home, Insured disagreed with Insurer's valuation and demanded an appraisal. The claim was submitted to appraisal, but Insurer did not pay Insured any additional amounts. Insured then demanded preaward interest on the appraisal award, arguing that interest accrued from the date of written notice of his fire claim and until the appraisal award was issued. When Insurer refused to pay, Insured brought this action. The district court concluded that Insured was not entitled to preaward interest. The court of appeals reversed, concluding that the policy language must "explicitly preclude" reward interest to avoid the obligation to pay preaward interest under section 549.09. The Supreme Court reversed, holding that a fire insurance policy provision stating that "no interest accrues on the loss until after the loss becomes payable" precludes preaward interest under section 549.09. View "Wesser v. State Farm Fire & Casualty Co." on Justia Law
St. Matthews Church of God & Christ v. State Farm Fire & Casualty Co.
In this insurance coverage dispute the Supreme Court held that State Farm Fire and Casualty Company was not required to cover repair costs to masonry under either Minn. Stat. 65A.10, subd. 1 or the State Farm policy at issue.Before the Supreme Court was the interpretation and application of Minn. Stat. 65A.10, subd. 1, which generally requires replacement cost insurance to cover the cost of repairing damaged property in accordance with state or local authorities' minimum code. Specifically in question was whether State Farm must cover the cost of repairing cracks in masonry that preexisted a storm that damaged the property of St. Matthews. Because the cracks violated the City of St. Paul's building code, the City would not allow St. Matthews to replace the drywall without also repairing the masonry. The district court granted summary judgment to State Farm, determining that because the storm did not damage the masonry, which led to the code upgrade requirements, no coverage existed. The Supreme Court affirmed, holding that, while State Farm was responsible for providing replacement cost coverage to the damaged drywall, it was not required to cover repair costs to the masonry. View "St. Matthews Church of God & Christ v. State Farm Fire & Casualty Co." on Justia Law
Else v. Auto-Owners Insurance Co.
The Supreme Court reversed the decision of the court of appeals in this appeal involving a dispute between a homeowner and an insurance company over prejudgment interest, holding that Minnesota standard fire insurance policy, Minn. Stat. 65A/01, entitled Homeowner to prejudgment interest in an amount that may result in a total recovery that exceeded the policy limit.Homeowner sought coverage from Insurer after fires damaged his home. Insurer denied coverage, leading Homeowner to bring this lawsuit. A jury found for Homeowner. The district court award awarded Homeowner prejudgment interest in a limited amount, finding that Homeowner's total recovery for his personal property loss could not permissibly exceed the policy coverage limit. The court of appeals affirmed. The Supreme Court reversed and remanded the case to the district court to recalculate prejudgment interest, holding that, consistent with past precedent interpreting the standard fire policy, prejudgment interest can lawfully begin accruing before ascertainment of the loss when the insurer denies all liability. View "Else v. Auto-Owners Insurance Co." on Justia Law
King’s Cove Marina, LLC v. Lambert Commercial Construction LLC
In this insurance dispute, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing the district court's determination that the insurance policy at issue covered all of the claimed property damage and that a Miller-Shugart settlement agreement was reasonable and unenforceable against Insurer, holding that the policy did not cover all of the claimed property damage.The court of appeals concluded that the settlement agreement was "unreasonable as a matter of law and unenforceable" against the insurer because the agreement failed to allocate between covered and uncovered claims. The Supreme Court reversed in part, holding (1) the policies in this case covered some, but not all, of the property damage claimed by the insured; and (2) determining the reasonableness of an unallocated Miller-Shugart settlement agreement involves a two-step inquiry set forth in this opinion. View "King's Cove Marina, LLC v. Lambert Commercial Construction LLC" on Justia Law
Koehnen v. Flagship Marine Co.
The Supreme Court held that a health care provider who did not intervene in an employee's pending workers' compensation proceeding after receiving adequate notice of the right to intervene cannot initiate a collateral attack on the compensation award under Minn. Stat. 176.271, .291 or Minn. R. 1420.1850, subp. 3B.Scott Koehnen was injured during the course and scope of his employment for Flagship Marine Company. Koehnen received chiropractic treatment from Keith Johnson. Johnson submitted his charges to the workers' compensation insurer for Koehnen's employer, but both the employer and insurer (collectively, Flagship Marine) denied liability for Koehnen's injury. When Koehnen filed a claim petition seeking workers' compensation benefits his attorney sent a notice informing Johnson of his right to intervene. Johnson, however, did not move to intervene, and the proceeding continued without him. Koehnen and Flagship Marine subsequently entered into a settlement agreement. The compensation judge approved the stipulation for settlement and issued an award on stipulation. Johnson later filed a petition for payment of medical expenses pursuant to section 176.271, .291.The compensation judge dismissed the petition, and the Workers' Compensation Court of Appeals affirmed. The Supreme Court affirmed, holding that because Johnson chose not to intervene his petition was correctly dismissed. View "Koehnen v. Flagship Marine Co." on Justia Law
Peterson v. Western National Mutual Insurance Co.
The Supreme Court affirmed the judgment of the district court awarding taxable costs for denying a first-party insurance claim in violation of Minn. Stat. 604.18, subd. 2(a), holding that the district court did not clearly err.After a bench trial, the district court found that Western National Mutual Insurance Company did not have a reasonable basis for denying Alison Joel Peterson's claim for insurance benefits and acted in reckless disregard of its lack of a reasonable basis in denying the claim. The Supreme Court affirmed, holding (1) the district court did not clearly err in determining that a reasonable insurer, who had the information that Western National had, would not have denied Peterson's claim for benefits; and (2) the district court did not clearly err by finding that Western National knew, or recklessly disregarded information that would have allowed it to know, that it lacked an objectively reasonable basis for denying benefits to Peterson. View "Peterson v. Western National Mutual Insurance Co." on Justia Law
Oliver v. State Farm Fire & Casualty Insurance Co.
In this dispute over the amount of loss after a fire occurred at the home of Respondents the Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the district court granting Respondents' motion to confirm an appraisal award but denying Respondents' motion for preaward interest as untimely, holding that the district court erred by applying the Minnesota Uniform Arbitration Act, Minn. Stat. 572B.01-.31, to a fire loss appraisal award.Respondents' home was insured against fire loss by Appellant. When Appellant and Respondent were unable to agree on the amount of the loss Respondents requested an appraisal. After an appraisal panel issued an award, which State Farm paid, Respondents sought confirmation of the appraisal and moved the court to grant preaward interest on the appraisal award. The superior court confirmed the appraisal award but denied the motion for preaward interest as untimely. The court of appeals reversed and remanded. The Supreme Court affirmed, holding (1) the Act did not apply to the appraisal process under the Minnesota Standard Fire Insurance Policy, Minn. Stat. 65A.01; and (2) a remand was necessary to allow the district court to determine whether Respondents were owed preaward interest and, if so, the amount of interest owed. View "Oliver v. State Farm Fire & Casualty Insurance Co." on Justia Law
Visser v. State Farm Mutual Automobile Insurance Co.
The Supreme Court affirmed the judgment of the district court holding that Appellant, who was injured while she was driving a Pontiac and sought additional primary underinsured motorist (UIM) benefits under an insurance policy that covered a separate vehicle, a Chevrolet, was not entitled to primary UIM benefits under the Chevrolet policy, holding that Appellant could not recover additional primary UIM benefits under the Chevrolet policy.State Farm, Appellant's insurer, paid Appellant the Pontiac policy's UIM benefits limit but denied that the Chevrolet policy applied to Appellant's claim for additional primary UIM benefits. The district court granted summary judgment for State Farm, holding that the Chevrolet policy did not apply under Minn. Stat. 65B.49, subd. 3a(5). The court of appeals affirmed. The Supreme Court affirmed, holding (1) consistent with section 65B.49, subdivision 3a(5) and precedent interpreting that provision, Appellant was limited to primary UIM benefits under the policy that covered the vehicle she occupied at the time of the accident; and (2) even assuming that parties can contract around the priority scheme for primary UIM benefits that the legislature established in section 65B.49, subdivision 3a(5), no explicit language in the State Farm policies actually did so. View "Visser v. State Farm Mutual Automobile Insurance Co." on Justia Law
Depositors Insurance Co. v. Dollansky
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing the claims filed by Depositors Insurance Company against Craig Dollansky after concluding that Depositors was barred by Minn. Stat. 60A.41(a) from proceeding against Dollansky in a subrogation action, holding that the statute indeed barred Depositors from proceeding in this action.Depositors insured a motor vehicle home owned by Karavan Trailers, Inc., which rented the motor home to Dollansky. The rental agreement provided that Dollansky was responsible for all damages to the RV during the term of the agreement. The motor vehicle caught fire while Dollansky was driving it. Karavan submitted a claim to its insurer, Depositors, which paid the full amount of the damages. Depositors then filed a complaint against Dollansky, alleging that Depositors was surrogated to the rights of Karavan in the same amount. The district court dismissed the claims, concluding that Depositors was barred by section 60A.41(a) from proceeding against Dollansky in a subrogation action. The court of appeals affirmed. The Supreme Court affirmed, holding that where Depositors provided insurance coverage to Dollansky as a permissive-use driver and the loss was caused by the nonintentional acts of Dollansky, section 60A.41(a) barred Depositors from proceeding against Dollansky in a subrogation action. View "Depositors Insurance Co. v. Dollansky" on Justia Law
Great Northern Insurance Co. v. Honeywell International, Inc.
Claims brought against the manufacturer of a component part of an improvement to real property fell under an exception to the ten-year statute of repose because the improvement was “machinery installed upon real property.” See Minn. Stat. 541.051.Appellant manufactured the motor in a home’s heat-recovery ventilator. Sixteen years after the ventilator was installed, a fire started in the ventilator, causing property damage to the home. Respondent, the insurer of the homeowners, brought this subrogation action against Appellant. The district court granted summary judgment for Appellant, concluding that the ten-year statute of response for improvements to real property barred every claim except the claim alleging a post-sale duty to warn, which claim it dismissed upon summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) under the plain language of section 541.051, the ventilator containing Appellant’s motor was “machinery installed upon real property,” and therefore, the court of appeals properly reinstated Respondent’s breach of warranty, negligence, and product liability claims; and (2) Appellant did not have a duty to warn consumers of its product’s alleged defect after the time of sale. View "Great Northern Insurance Co. v. Honeywell International, Inc." on Justia Law
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