Justia Insurance Law Opinion Summaries

First American Title Insurance Company issued title insurance policies to the predecessors of North Fork Land & Cattle, LLLP. When North Fork learned that Bunker Road, which crosses three of North Fork’s properties, was established as a county road, North Fork submitted notices of claims under the title insurance policies, asserting that First American failed to disclose to one of North Fork’s predecessors that Bunker Road burdened the properties and that it was damaged by the Bunker Road encumbrance. First American did not respond to North Fork’s claims, and North Fork filed suit against First American. The district court granted summary judgment in favor of First American, concluding that North Fork did not meet the definition of “insured” under the title insurance policies. The Supreme Court reversed, holding that North Fork is a covered insured under the terms of the title insurance policy. Remanded. View "N. Fork Land & Cattle, LLLP v. First Am. Title Ins. Co." on Justia Law

Keizer Trailer Sales, Inc., which was insured by Continental Western Insurance Company (CWIC), sold three trailers to James Black. The installment purchase agreement stated that Keizer would remain the owner of the trailers under the purchase price was paid in full. Black was subsequently involved in an accident while pulling a Keizer trailer that resulted in one fatality and multiple injuries. Wrongful death and negligence claims were filed against Black and his business. CWIC filed a complaint for declaratory judgment seeking a declaration that the commercial and umbrella policies it issued to Keizer on the trailer involved in the accident did not provide coverage for the claims arising from Black’s accident. The district court ruled against CWIC, concluding that Black was insured under the policies’ omnibus clauses because he was driving a vehicle owned by Keizer with Keizer’s permission. The Supreme Court affirmed, holding that because Keizer retained ownership of the trailers, and because Black’s use of the trailers was with Keizer’s permission, coverage was available under the omnibus clauses of Keizer’s CWIC policies. View "Continental W. Ins. Co. v. James Black, JJ Bugs, Ltd." on Justia Law

In 2004, Appellant fell while working and strained her back. Appellant was awarded worker’s compensation benefits. In 2009, Appellant slipped and fell at work and injured her ankle. In 2010, Appellant sought temporary total disability and medical pay benefits from the Workers Compensation Division, which denied Appellant’s requests. After a contested case hearing, the Office of Administrative Hearings (OAH) upheld the Division’s denial of Appellant’s request for benefits, concluding Appellant did not meet her burden of proving that she suffered aggravation of a preexisting back condition as a result of a work related injury or that she suffered a second compensable injury. The district court affirmed. The Supreme Court affirmed, holding that the OAH did not err by failing to find a causal connection between the 2009 workplace incident and Appellant’s delayed back pain. View "Hirsch v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Forsberg Engerman Co., an insurance agency, helped Lewis Holding Co., a trucking business, purchase insurance from Lexington Insurance Co. In 2011, one of Lewis Holding’s trailers was damaged. After Lewis Holding filed an insurance claim, NTA, Inc.’s adjuster examined the trailer and determined that the damage was due to mechanical failure or wear and tear. Lexington denied the insurance claim on the grounds that the damages were not the result of an upset or collision, but rather, the result of improper welding. Lewis Holding subsequently filed suit against Lexington, NTA, and Forsberg. The district court granted summary judgment for Defendants. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment for Defendants where (1) the insurance agreement plainly and unambiguously excluded coverage for damages due to mechanical failure; (2) Forsberg, who was not a party to the insurance contract, could not be held liable under the insurance policy; and (3) Defendants had reasonable bases for denying Lewis Holding’s claim. View "Lewis Holding Co., Inc. v. Forsberg Engerman Co." on Justia Law

Appellants purchased property that was subject to a Master Plan that restricted the use and development of the property. Appellants obtained title insurance from Insurer, but the policy did not mention the Master Plan. Appellants only later learned of the Master Plan when they were informed they were in violation of the Master Plan and faced substantial penalties if they failed to comply with the Plan. Appellants sued Insurer, claiming a breach of the terms of the title insurance policy, negligence, and bad faith. The district court granted summary judgment in favor of Insurer on all claims brought in Appellants' complaint. The Supreme Court affirmed, holding that the district court did not err in entering judgment in favor of Insurer. View "Sonnett v. First Am. Title Ins. Co." on Justia Law

The Wyoming Workers' Safety and Compensation Division awarded benefits to Appellant after he experienced a workplace injury. The Division denied Appellant's claim for payment for prescription medication he alleged was related to his workplace injury. The Medical Commission upheld the Division's determination, and the district court affirmed. The Supreme Court affirmed, holding (1) the Commission's decision upholding the Division's denial of benefits was supported by substantial evidence; and (2) the Commission applied the proper burden of proof for a second compensable injury when it required Appellant to establish a causal connection between his abdominal pain and his ingestion of the prescription medication at issue. View "Jacobs v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

The Wyoming Workers' Safety and Compensation Division determined that Appellant suffered a compensable injury while employed by Employer. The lodge filed an objection to that determination and requested a hearing with the Office of Administrative Hearings (OAH). Appellant filed a motion to dismiss that objection on the grounds that the objection was invalid because Employer was not a proper party to the action. The OAH denied Appellant's motion and concluded that Appellant had not suffered a compensable injury. The district court affirmed. At issue on appeal was whether Employer properly filed an objection to the Division's final determination of compensability. The Supreme Court affirmed, holding that Employer was a proper party to the action because it was the identified employer and paid the necessary contributions under Wyoming Worker's Compensation Act. View "Heikkila v. Signal Mountain Lodge" on Justia Law

Appellant was injured in an accident that occurred during the course of her employment. After receiving a permanent partial impairment award from the Wyoming Worker's Compensation Division, Appellant sought permanent partial disability benefits. The Division denied Appellant's application, stating that she had not complied with the statutory work search requirements. After a contested case hearing, the Office of Administrative Hearings granted summary judgment for the Division, concluding that Appellant had not timely submitted documentation showing she had sought work. The district court affirmed. The Supreme Court reversed, holding (1) Appellant's work search submission was timely; and (2) Appellant was entitled to a hearing and the opportunity to present evidence showing that she actively sought work. View "Stallman v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

This appeal arose out of Ryan Dorman's petition for an extension of his worker's compensation temporary total disability (TTD) benefits and for reimbursement of travel expenses incurred in travelling from Idaho to Cheyenne to obtain medical care. In May 2006, Dorman sought treatment from an Idaho physician for treatment of his alleged work-related injury. Due to the nature of Dorman's injury, he consulted multiple physicians, first in Idaho, then in Wyoming. With each consultation, the doctors indicated that the injury was outside of their scope of expertise, and referred Doman to another specialist. During the period that Dorman was changing physicians, the Division and Dorman negotiated a stipulation concerning his TTD benefits and other benefits. This followed OAH and district court decisions that largely reversed the Division's earlier determinations concerning TTD benefits and Dorman's need for continued medical treatment. The Stipulated Order also provided that medical benefits would be paid as directed by the district court's order. After the Division paid the stipulated TTD benefits, Dorman submitted a letter to the Division requesting extended benefits The Division thereafter issued a final determination denying them, and further denied several applications for travel expense reimbursement for Dorman's trips to Idaho and Cheyenne. The matters were referred to the OAH where a combined hearing was held on the denial of TTD benefits, denial of travel reimbursement, and denial of diagnostic testing related to Dorman's injury. The OAH upheld the denial of TTD benefits on the ground that Dorman had failed to make the required showing that the Idaho and Cheyenne doctors were the closest available medical providers. Dorman appealed the portion of the OAH order denying extended TTD benefits and travel reimbursement to the district court. Upon review, the Supreme Court affirmed the OAH denial of the travel reimbursement: Dorman could not prove that reimbursement of travel expenses was not supported by substantial evidence and in accordance with law. View "Dorman v. Wyoming" on Justia Law

The Wyoming Workers' Safety and Compensation Division awarded benefits to Appellant Gary Mitcheson after he fell at work and injured his tailbone in July of 2007. Approximately two years later, the Division issued a final determination denying payment for medical care that Appellant claimed was related to his workplace injury. Appellant requested a contested case hearing, and the Office of Administrative Hearings (OAH) upheld the Division's determination. Appellant appealed to the district court, which upheld the OAH's order. On appeal, Appellant challenged the OAH order contending: (1) the order was arbitrary and unsupported by substantial evidence; (2) the OAH's denial of payment for treating Appellant's tailbone was arbitrary; and (3) the OAH order denying payment for medical care contrary to the "Rule Out" rule was contrary to law. Finding the issues Appellant raised on appeal to be without merit, the Supreme Court affirmed the OAH's decision. View "Mitcheson v. Wyoming" on Justia Law