Justia Insurance Law Opinion Summaries

In the Supreme Court of Wyoming, an appeal by Ronald Pinther, a former insurance agent, was dismissed. Pinther had worked for American National Property and Casualty Insurance Company (ANPAC) and American National Insurance Company (ANICO). He filed a lawsuit against ANPAC, ANICO, and another agent, Philip Maggard, claiming breach of contract, breach of good faith and fair dealing, fraudulent inducement, promissory estoppel, civil conspiracy, and age discrimination. The district court granted summary judgment in favor of ANPAC and Mr. Maggard. On appeal, the Supreme Court held that the district court had not erred in its decision. The court found that Mr. Pinther's breach of contract claim against ANPAC was governed by the Post-Termination Compensation Schedule outlined in the agent agreement. The court further held that Mr. Pinther's claim of a breach of an implied duty of good faith and fair dealing could not be maintained given the at-will nature of the agency contract. The court also dismissed Mr. Pinther's fraudulent inducement claim against ANPAC, noting that the recruiting brochure did not govern his agreement with ANPAC. The court further held that Mr. Pinther's claim for tortious interference with a contract against Mr. Maggard could not be maintained as the actions of Mr. Maggard, as an agent of ANPAC, were imputed to ANPAC. Lastly, the court held that Mr. Pinther's civil conspiracy claims against ANPAC and Mr. Maggard failed as the underlying tort claims did not survive summary judgment. View "Pinther v. American National Property and Casualty Insurance Company" on Justia Law

In this case heard by the Supreme Court of the State of Wyoming, the plaintiff, Scherri Hacker, made a conversion claim against Hacker Oil, Inc., which had paid premiums on a whole life insurance policy on her husband, James Hacker. The policy was executed as a split-dollar arrangement, with the intention that upon Mr. Hacker's death, Hacker Oil would be reimbursed for the paid premiums, and the remaining death benefits would be distributed to Mrs. Hacker. After Mr. Hacker's death, Hacker Oil received $125,000 and half the interest accrued under the policy, which exceeded the $55,048 it had remitted in premium payments.The defendant, Hacker Oil, appealed the district court's decision, arguing that Mrs. Hacker had failed to mitigate her damages by withholding her signature from a letter agreement and by asserting a conversion claim against Hacker Oil. The court, however, upheld the district court's ruling, finding that Mrs. Hacker did not have a duty to mitigate her damages. The court determined that Mrs. Hacker's failure to sign the letter agreement prior to Hacker Oil's signing and submission of a claim to the insurance company did not constitute a failure to mitigate damages. The court further concluded that once Hacker Oil committed the conversion, Mrs. Hacker rightfully brought a claim and asserted her rights. Thus, the Supreme Court of the State of Wyoming affirmed the district court's decision, holding that Hacker Oil had wrongfully converted $70,372.68, the difference between the amount it received and the amount it was entitled to receive. View "Hacker Oil, Inc. v. Hacker" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of C.H. Yarber Construction in this action brought by West American Insurance Company seeking subrogation and asserting claims of negligence and breach of contract, holding that West could not pursue its claims against C.H. Yarber in subrogation.C.H. Yarber was the tenant leasing Profile Properties' commercial property in Cheyenne when the property sustained damage from a fire. West, the insurer of the property, covered Profile's fire damages and proceeded against C.H. Yarber in subrogation. The district court concluded that West could not pursue its claims in subrogation because D.H. Yarber was a co-insured under Profile's insurance policy. The Supreme Court affirmed, holding that because the relevant lease evidenced that Profile did not intend to look to C.H. Yarber to cover the insured loss, West could not pursue its claims against C.H. Yarber in subrogation. View "West American Insurance Co. v. Black Dog Consulting Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Laramie Investment Company and its owner and president, Brad Jackson (collectively, Defendants), and dismissing Plaintiffs' action for breach of contract, negligence, and "reasonable expectations," holding that there was no error in the proceedings below. Plaintiffs, who contracted with Defendants to obtain an insurance policy for their ranch and surrounding outbuildings, brought this suit two years after a tornado destroyed their home and an outbuilding. Plaintiffs discovered that the insurance policy did not cover the outbuilding or its contents but did not bring suit until the two-year anniversary of the tornado. The district court granted summary judgment for Defendants on statute of limitations grounds. The Supreme Court affirmed, holding (1) Jackson was a "professional" under Wyo. Stat. Ann. 1-3-107; (2) the statute of limitations began running when the insurance policy was issued; (3) the district court correctly granted Defendants' motion for summary judgment; and (4) the "continuous care doctrine" did not apply to the facts of this case. View "Falkenburg v. Laramie Investment Co." on Justia Law

The Supreme Court reversed in part and affirmed in part the decision of the district court granting summary judgment for Meritain Health, Inc., and dismissing David Peterson's claims against Meritain, holding that there were genuine issues of material fact as to some of Peterson's claims.Peterson, an insured under a hospital's health benefit plan, brought this action against the hospital and Meritain Health, Inc., the third-party administrator of the plan, alleging several claims arising from the denial of his claims for health insurance coverage. The district court granted Meritain's motion for summary judgment. The Supreme Court reversed in part and remanded the case, holding that there were genuine issues of material fact regarding Peteron's breach of contract claim, his third-party beneficiary claim, and his claim for breach of the covenant of good faith and fair dealing. View "Peterson v. Meritain Health, Inc." on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of State Farm Mutual Automobile Insurance Company and dismissing Plaintiffs' claim alleging that they were entitled to uninsured motor vehicle (UIM) benefits after they were injured in an automobile accident caused by another driver, holding that State Farm was entitled to judgment as a matter of law.After their accident, Plaintiffs filed claims with State Farm for full UIM benefits of $100,000 after settling with the tortfeasor's insurance company. When State Farm did not respond, Plaintiffs brought suit, asserting breach of contract, bad faith in delaying and denying payment for the benefits, and breach of the implied covenant of good faith and fair dealing. The district court granted summary judgment for State Farm. The Supreme Court affirmed, holding that under the unambiguous language of the State Farm insurance policy, Plaintiffs were not entitled to UIM benefits and were not entitled to relief on their claims. View "Bergantino v. State Farm Mutual Automobile Insurance Co." on Justia Law

The Supreme Court answered in the affirmative a question certified to it by the United States Court of Appeals asking whether an insurance policy is "issued for delivery" or "delivered" under Wyo. Stat. Ann. 26-15-101(a)(ii) even if not copy was conveyed to Wyoming and the police listed only an out-of-state address for the insured.Specifically, the Supreme Court held (1) for purposes of Wyo. Stat. Ann. 26-15-101(a)(ii), an insurance contract is "delivered" in Wyoming if it is actually or constructively delivered in Wyoming, and an insurance contract is "issued for delivery" where the policy was intended to be delivered; and (2) absent an insurance contract unambiguously stating otherwise, if the location of the insured and the location of the risk to be insured are both in Wyoming, an insurance policy is intended to be delivered and is issued for delivery in Wyoming. View "Sinclair Wyoming Refining Co. v. Infrassure, Ltd" on Justia Law

In this case alleging that Memorial Hospital of Sweetwater County was vicariously liable for the acts or omissions of a physician who worked at the hospital as an independent contractor, the Supreme Court reversed the judgment of the district court finding that the Hospital waived its immunity by purchasing liability insurance. The Hospital had moved for summary judgment on the ground that the physician was not a Hospital employee, and therefore, the Hospital was immune from liability for his acts or omissions. The district court denied the Hospital’s motion, finding that the Hospital waived its immunity to ostensible agency claims under the insurance exception at Wyo. Stat. Ann. 1-39-118(b). The Supreme Court reversed, holding (1) the Hospital’s liability insurance did not provide coverage for liability beyond the liability defined by the Wyoming Governmental Claims Act, and (2) the Hospital’s liability insurance therefore did not extend the Hospital’s liability to include liability for its apparent agents. View "Memorial Hospital of Sweetwater County v. Menapace" on Justia Law

Larry Hurst was killed and Sara Hurst was seriously injured while riding their bicycles after a vehicle driven by Hannah Terry struck each of their bicycles. The Hurst filed a claim with their uninsured motorist insurance carrier, Metropolitan Property and Casualty Insurance Company (MetLife), which contended that the injuries to the Hursts were the result of one accident, resulting in a maximum of $300,000 in coverage. The Hursts, however, argued that their injuries were the result of two accidents, warranting $600,000 in coverage. The district court granted summary judgment in favor of MetLife, concluding that there was only one accident for purposes of determining the amount of uninsured motorist coverage. The Supreme Court reversed, holding that the record was insufficient for a legal conclusion as to whether Terry maintained or regained control of her vehicle during the collisions with the Hursts, and therefore, summary judgment was improperly granted and the matter must be remanded for trial. View "Hurst v. Metropolitan Property & Casualty Insurance Co." on Justia Law

Jim Hipner, LLC (Hipner), a trucking company, obtained an umbrella policy from Century Surety Company (Century) that contained a notice provision stating that the insured will notify Century “as soon as practicable” of an occurrence, offense, or injury. When one of Hipner’s drivers produced a multi-vehicle collision (the accident) that resulted in a serious injury, Century filed suit in federal court seeking a declaratory judgment that it did not have an obligation to defend or indemnify Hipner in connection with any claims relating to the accident because Hipner failed to provide written notice “as soon as practicable.” The district court concluded that Century received timely notice under the policy as a matter of Wyoming law. Century appealed, and the United States Court of Appeals for the Eighth Circuit certified a question to the Wyoming Supreme Court regarding the enforceability of the insurance policy notice provision. The Supreme Court answered that, under Wyoming law and regardless of the express language of the insurance policy, an insurer must be prejudiced before being entitled to deny coverage when the insured has failed to give notice “as soon as practicable.” View "Century Surety Co. v. Jim Hipner, LLC" on Justia Law