Justia Insurance Law Opinion Summaries

In this uninsured motorist case, plaintiff appealed the district court's ruling that the uninsured motorist (UIM) provisions in his insurance policies with defendant could not be stacked beyond the statutory minimum per insurance policy. Plaintiff also argued that the district court erred in applying a settlement that arose from the same accident at issue in this case as a credit against what he could recover from defendant. Defendant cross-appealed, arguing that plaintiff's counsel's misconduct before the jury warranted a new trial. In addition, defendant argued that plaintiffs failed to make a submissible negligence case to the jury. The court affirmed the judgment of the district court as to all issues save its determination that UIM provisions could not be stacked beyond the statutory minimum. As to that issue, the court reversed and remanded. View "Burroughs, et al. v. Mackie Moving Systems Corp., et al." on Justia Law

In a diversity action involving an insurance dispute, Union Electric appealed the district court's grant of EIM's motion to dismiss. Union Electric is a Missouri Utility and EIM is a mutual insurance company incorporated in Barbados and with a principal place of business in Florida. At issue was an insurance contract, which specified that New York law applied, which was drafted by the member insureds, in contrast to the insurer-drafted contracts commonly found in insurance disputes. While the district court correctly determined that M/S Bremen v. Zapata Off-Shore Co. provided the standard for evaluating a motion to dismiss based on a contractual forum selection clause, the court reversed and remanded for the district court to consider in the first instance whether Missouri's public policy against the enforcement of mandatory arbitration provisions invalidated the forum selection clause. View "Union Electric Co. v. Energy Ins. Mutual" on Justia Law

Eloise Walker, mother of the decedent, appealed the grant of summary judgment in favor of Pamela Wright-Dallas, the named beneficiary under the decedent's benefits plans. Walker argued that the district court erred because it made a ruling without first reviewing the entire administrative record, and in the alternative, the district court erred by applying the wrong standard of review. The court found no plain error and rejected Walker's claim that the district considered an inadequate record; the district court properly applied the abuse-of-discretion standard; and a heightened standard of review was not warranted. Accordingly, the court affirmed the judgment. View "Trustees of the Local No. 1, et al. v. Walker" on Justia Law

Perks applied for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. An ALJ denied Perks's application. On appeal to the appeals council, Perks submitted additional evidence. The appeals council noted the receipt of the additional evidence but denied further review of Perks's claim. The district court affirmed. The Eighth Circuit Court of Appeals affirmed, holding (1) substantial evidence supported the ALJ's finding that Perks was not disabled; and (2) the additional evidence submitted to the appeals council did not undermine the ALJ's determination, as the ALJ would not have reached a different result with the additional evidence and the ALJ's decision was supported by substantial evidence in the record as a whole. View "Perks v. Astrue" on Justia Law

Joseph Terry, who received long-term disability benefits, filed a Chapter 7 bankruptcy petition. Terry later sued the bankruptcy trustee, seeking a declaration that his disability insurance provider, Standard Insurance Company, should not have reduced his benefits by the amount of certain "voidable" payments. The bankruptcy court ruled that Standard was precluded from recouping the payments. The bankruptcy appellate panel (BAP) reversed, holding that recoupment was subject to a a "balancing of the equities." On remand, the bankruptcy court found that the equities prevented Standard from recouping the payments. The Eighth Circuit Court of Appeals reversed, holding that the BAP (1) erred by introducing a balancing of the equities test into the doctrine of recoupment and by invoking these equitable principles to deny Standard a right of recoupment; and (2) abused its discretion in how it weighed the equities. View "Terry v. Standard Ins. Co." on Justia Law

Plaintiff Marnita Goddard was injured while riding on a trolley operated by the city of Deadwood, South Dakota. Invoking diversity jurisdiction, Goddard sued the city for negligence and the South Dakota Public Assurance Alliance (SDPAA) for uninsured motorist coverage. After Goddard settled with the city, the district court granted summary judgment in favor of SDPAA, concluding that Goddard was not covered under the uninsured motorist provision in the city's agreement with SDPAA. The Eighth Circuit Court of Appeals affirmed, holding that Goddard had not shown she was entitled to coverage under the uninsured motorist provision of the SDPAA agreement. View "Goddard v. S.D. Pub. Assurance Alliance" on Justia Law

Kevin Byes applied for disability insurance benefits and supplemental security income on July 30, 2007, claiming disability since November 1, 2005. The Commissioner of Social Security Administration (Commissioner) denied benefits. An administrative law judge (ALJ) upheld the Commissioner's decision, concluding that Byes was not disabled from November 1, 2005 through the date of the decision. The district court agreed with the ALJ's decision. The Eighth Circuit Court of Appeals affirmed, holding that substantial evidence supported the ALJ's finding of no severe mental impairment; and (2) the district court correctly concluded that the ALJ had applied the incorrect grid rule in order to determine Byes was not disabled but that the error was harmless. View "Byes v. Astrue" on Justia Law

Alpine Glass, Inc. appealed the district court's partial denial of Alpine's motion to consolidate 482 short-pay claims for arbitration against the Country Mutual Insurance Co. and five of its subsidiaries. The Eighth Circuit Court of Appeals dismissed Alpine's appeal for lack of appellate jurisdiction, holding (1) the Court lacked jurisdiction to hear the appeal under 28 U.S.C. 1291 because the district court's order was not a final order; and (2) the denial of a motion to consolidate arbitrations does not imperil a substantial public interest sufficient to warrant jurisdiction under the collateral order doctrine, and therefore, the order was not appealable under the collateral order doctrine. View "Alpine Glass, Inc. v. Country Mut. Ins. Co." on Justia Law

Patrick McGinness, driving a vehicle owned by his adult daughter, negligently struck and injured Marie DeMeo. DeMeo obtained a $350,000 state-court judgment against McGinness. McGinness's daughter's insurer, American Family Insurance Company, paid its $100,000 policy limit under an owner's liability policy that covered McGinness as a permitted driver. State Farm insured McGinness under four liability policies issued for the cars he owed. Each policy provided coverage to McGinness when operating a non-owned vehicle such as his daughter's. Invoking the policies' "anti-stacking" provisions, State Farm paid the per-person limit of one policy, $50,000. De Meo filed this action to recover an additional $150,000, the combined limits of the other three policies. The district court held that the anti-stacking provisions did not conflict with Missouri's Motor Vehicle Financial Responsibility Act (MVFRL) requirements, which mandate that motor vehicle owners and operates maintain minimum levels of financial responsibility for damages arising out of their ownership or use of a motor vehicle, and granted summary judgment in State Farm's favor. The Eighth Circuit Court of Appeals affirmed, holding that there was no basis to conclude that the MVFRL demands stacking when there are multiple policies. View "DeMeo v. State Farm Mutual Auto. Ins. Co." on Justia Law

Robert and Ethel Youngs' home and personal property were insured under a policy issued by Allstate Insurance Company. The policy provided that Allstate would "not cover any loss or occurrence in which any insured person has concealed or misrepresented any material fact or circumstance." After a fire broke out in the Youngs' garage, damaging or destroying many of its contents, AllState denied the Youngs' insurance claim, asserting that the Youngs misrepresented material facts regarding their losses. The Youngs filed suit against Allstate for breach of contract and vexatious refusal to pay. The district court granted summary judgment for Allstate. The Eighth Circuit Court of Appeals reversed, holding that there were genuine issues of fact for trial. View "Young v. Allstate Ins. Co. " on Justia Law