Justia Insurance Law Opinion Summaries

Jacob Plassmeyer incurred medical expenses during a collegiate baseball practice, and his college provided its student athletes insurance with FA. Jacob's father was also insured by the Dakotas, an employee welfare benefit plan, and Jacob was covered under this Employee Retirement Income Security Act (ERISA) plan as a dependent of his father. In this case, the trustees of Dakotas brought this declaratory judgment action against FA under section 502(a)(3) of ERISA, 29 U.S.C. 1132(a)(3), seeking an order enforcing the coordination of benefits (COB) provisions in the Dakotas plan by declaring that FA's policy provided primary coverage of Jacob's claim for medical expenses already incurred. The district court denied FA's motion to dismiss and granted Dakotas' motion for summary judgment. The Eighth Circuit held that a declaratory judgment action to enforce the Dakotas plan as it applied to the claim for benefits was both consistent with the plain language of section 502(a)(3), as construed in light of historical equitable remedies available to trustees; the court agreed with the district court that FA's coverage was primary; but the district court abused its discretion in awarding attorney fees. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Dakotas and Western Minnesota Electrical Industry Health & Welfare Fund v. First Agency, Inc." on Justia Law

HRA appealed the district court's order declining to grant pre-award interest on an insurance appraisal award. The Eighth Circuit reversed and remanded, holding that the Minnesota Supreme Court subsequently ruled that Minnesota Statute section 549.09 provides for pre-award interest on such awards. On remand, the district court may decide in the first instance how to calculate the pre-award interest. View "Housing and Redevelopment Authority of Redwood Falls v. Housing Authority Property Insurance" on Justia Law

The Eighth Circuit affirmed the district court's decision upholding National Union's denial of benefits. The court held that National Union did not abuse its discretion in denying plaintiff's claims for accidental death and spousal benefits, because National Union's interpretation of the policy was not unreasonable. In this case, the policy gave National Union full discretionary authority to interpret its terms. View "Donaldson v. National Union Fire Insurance Co." on Justia Law

The Eighth Circuit affirmed the district court's denial of the insurers' motion to dismiss, reversed and vacated the award of prejudgment interest, and affirmed the rejection of Simmons' claims for statutory damages and attorney fees. The court applied Arkansas law and held that the district court properly denied the insurers' motion to dismiss because Simmons's suit was timely. However, the district court's entry of judgment and prejudgment interest was not appropriate where Simmons' damages were not capable of exact determination until the jury spoke. Finally, the district court properly denied Simmons' request for statutory damages and attorney fees, because Simmons did not recover the statutory threshold of at least 80% of the amount it demanded in the suit. View "Simmons Foods, Inc. v. Industrial Risk Insurers" on Justia Law