Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

A father and daughter jointly owned a house in Alabama but had a contentious relationship, with both warning their insurer, USAA General Indemnity Co., that the other might intentionally set fire to the property. Despite these warnings, USAA issued a $500,000 policy covering both as insureds. The policy included an exclusion that denied coverage to all insureds if any one of them intentionally caused a loss, except in certain cases of domestic abuse. Shortly after the policy was issued, the house was destroyed by fire. The father, Martin D. Renfroe, filed a claim, but USAA denied coverage, suspecting arson by either Renfroe or his daughter.The United States District Court for the Northern District of Alabama considered Renfroe’s claims for breach of contract and bad faith. The court ruled that the innocent-insured exclusion was void as against Alabama public policy, allowing Renfroe’s breach of contract claim to proceed to trial, but granted summary judgment for USAA on the bad faith claim due to evidence suggesting Renfroe might have committed arson. At trial, the jury found in favor of Renfroe, awarding him damages, which the court later reduced.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that Alabama law does not prohibit innocent-insured exclusions in insurance policies unless specifically barred by statute, and found no such bar here. The appellate court concluded the exclusion was enforceable, vacated the district court’s judgment on the breach of contract claim, and remanded for a new trial. The Eleventh Circuit affirmed the district court’s summary judgment for USAA on the bad faith claim, holding that USAA had at least an arguable basis for denying coverage due to evidence implicating Renfroe in arson. View "Renfroe v. USAA" on Justia Law

An individual was fatally electrocuted while installing rebar at a construction site where H&M Builders, LLC served as a subcontractor. H&M was insured by Mt. Hawley Insurance Company, which had issued a commercial general liability policy valid on the date of the incident. The decedent’s estate, represented by Gloria Escalante, filed a wrongful death lawsuit in Florida state court against H&M and others, alleging their negligence led to the fatality. Mt. Hawley undertook H&M’s legal defense in the state proceeding, but did so under a reservation of rights, disputing its obligation to defend or indemnify H&M.Subsequently, Mt. Hawley initiated a federal action in the United States District Court for the Southern District of Florida, seeking a declaratory judgment that it owed no duty to defend or indemnify H&M in the underlying state litigation. The district court granted summary judgment in favor of H&M and Escalante on the duty-to-defend issue, while reserving judgment on the duty to indemnify until the state case concluded. Mt. Hawley appealed this summary judgment order before the district court entered a final judgment. While the federal appeal was pending, the parties settled the state wrongful death case, which was then dismissed. The district court then dismissed the indemnification claim as moot and entered final judgment.The United States Court of Appeals for the Eleventh Circuit held that it lacked jurisdiction over Mt. Hawley’s appeal for three separate reasons: the underlying state-court action had been settled and dismissed, eliminating any live controversy; the summary judgment order appealed from did not possess injunctive qualities necessary for interlocutory appellate jurisdiction under 28 U.S.C. § 1292(a)(1); and, finally, the district court had entered a final judgment, so any appeal should be from that judgment rather than an interlocutory order. The appeal was therefore dismissed for lack of jurisdiction. View "Mt. Hawley Insurance Company v. H&M Builders, LLC" on Justia Law

The case concerns an Alabama resident who was injured by an uninsured motorist while riding his motorcycle. At the time, he held two separate insurance policies: a standard auto insurance policy from GEICO covering his motorcycle, and a specialty policy from Essentia Insurance Company covering his antique truck. The GEICO policy provided uninsured motorist coverage as required by Alabama law, and the insured collected $25,000 under it. Essentia’s policy, which covered only the antique vehicle, excluded uninsured motorist coverage for accidents involving vehicles other than the covered antique truck. The policy also required the insured to maintain a separate insurance policy that satisfied Alabama’s minimum coverage requirements.After Essentia denied his claim for uninsured motorist coverage, the insured brought suit in the United States District Court for the Middle District of Alabama. Essentia moved for summary judgment, arguing that its specialty policy’s coverage exclusion was valid because the insured had other coverage meeting Alabama’s requirements. The district court denied Essentia’s motion in part, holding Essentia liable for uninsured motorist benefits, but limited the liability to the statutory minimum of $25,000, and entered judgment accordingly. Essentia appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment de novo and reversed. The Eleventh Circuit held that Alabama law permits insurers to fulfill mandatory coverage requirements through multiple policies, and that Essentia’s exclusion is enforceable so long as the insured has other coverage meeting statutory requirements. The court remanded the case for further proceedings consistent with its opinion. View "Clayton v. Essentia Insurance Company" on Justia Law

A company operating a railroad in Florida took precautionary measures in anticipation of Hurricane Irma in 2017 by removing and later reinstalling crossing gates at approximately 600 locations to prevent storm-related damage. These actions caused operational delays and additional expenses, but ultimately prevented significant physical damage. The company submitted a claim for these expenses, totaling over $5.6 million, under its property insurance policy covering direct physical loss, time element losses, and certain preventative measures. The insurers denied the claim, contending the deductible applicable to hurricane-related events exceeded the claimed amount.The United States District Court for the Middle District of Florida reviewed the insurance policy and determined that only the provisions related to “Protection and Preservation of Property” applied, not broader coverage provisions. The court concluded that the “Named Windstorm” deductible of 5% of the property value at all affected locations applied, resulting in a deductible of over $10.9 million, which surpassed the company’s losses. Consequently, the district court granted summary judgment to the insurers.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the relevant coverage provisions were indeed those for “Protection and Preservation of Property,” but determined that the correct deductible was $750,000, not the higher amount calculated by the district court. The Court of Appeals found that since there was no actual physical damage to the properties, the policy did not require the 5% calculation, and the minimum deductible applied. The appellate court affirmed the district court’s identification of the applicable coverage, vacated the summary judgment based on the deductible calculation, and remanded the case for further proceedings to determine the amount recoverable after the $750,000 deductible. View "Florida East Coast Holdings Corporation v. Lexington Insurance Company" on Justia Law

A hotel owner in Georgia faced a lawsuit brought by J.G., who alleged that she suffered injuries from being sex trafficked by third parties at the hotel between 2018 and 2019. The owner was insured under a commercial policy with an insurer, which included both general liability and personal and advertising injury coverage. The policy also contained two relevant endorsements: one excluded coverage for injuries arising from “abuse or molestation,” and the other limited or excluded coverage for injuries resulting from assault or battery offenses.After J.G. filed her lawsuit, the insurer provided the hotel with a defense, subject to a reservation of rights. Subsequently, the insurer initiated a declaratory judgment action in the United States District Court for the Northern District of Georgia, seeking a ruling that it did not owe coverage for J.G.'s claims under the policy. The hotel moved to dismiss the insurer’s complaint, arguing that the duty to indemnify was not ripe because liability had not yet been determined in the underlying action, and that the duty to defend existed because the allegations potentially fell within the policy’s coverage.The District Court evaluated the complaint and concluded that the insurer had a duty to defend the hotel in the underlying action, as the allegations in J.G.’s complaint potentially triggered coverage and the endorsements did not unambiguously bar or limit coverage. However, the court found the request for a declaration regarding the duty to indemnify was not ripe and retained jurisdiction over that issue. The insurer appealed, arguing the district court’s order was immediately appealable as an injunction. The United States Court of Appeals for the Eleventh Circuit held that the order was not final nor did it have the practical effect of an injunction, and therefore dismissed the appeal for lack of jurisdiction. View "Northfield Insurance Co. v. North Brook Industries, Inc." on Justia Law

After a boat owned by Bryan and Bethea Crabtree was severely damaged by fire while in storage in Florida, the Crabtrees sought coverage under their insurance policy with Great Lakes Insurance. Great Lakes denied their claim, alleging noncompliance with policy conditions, and subsequently filed a declaratory judgment action against the Crabtrees in the United States District Court for the District of Montana, based on the policy’s forum-selection clause and the Crabtrees’ Montana address.The parties agreed that Great Lakes would voluntarily dismiss the Montana case and refile in the United States District Court for the Southern District of Florida (SDFL), with the understanding that the Crabtrees would not contest jurisdiction or venue. Great Lakes dismissed the Montana action and refiled in SDFL. In response, the Crabtrees initiated a state court action and moved to stay or dismiss the SDFL federal suit. Instead of opposing the motion, Great Lakes voluntarily dismissed the SDFL suit as well. That same day, Great Lakes refiled a third action in Montana, which was later transferred back to SDFL at the Crabtrees’ request and with Great Lakes’s consent.Upon return to SDFL, the United States District Court for the Southern District of Florida considered whether, under Federal Rule of Civil Procedure 41(a)(1)(B), Great Lakes’s second voluntary dismissal barred further litigation of the same claim. The court granted summary judgment for the Crabtrees, holding that Rule 41(a)(1)(B) means what it says: a second voluntary dismissal acts as an adjudication on the merits, i.e., a dismissal with prejudice, even if the first dismissal was by agreement. The United States Court of Appeals for the Eleventh Circuit affirmed, concluding that Great Lakes was precluded from relitigating its claim in SDFL. View "Great Lakes Insurance SE v. Crabtree" on Justia Law

Selina Anderson, a federal employee with a history of severe lung disease, broke her leg in a parking lot accident and subsequently died less than a week later following complications from surgery. Her official cause of death was a pulmonary embolism, but her autopsy noted that her longstanding interstitial lung disease contributed to her death. Anderson’s daughter, Brittany Finney, was the beneficiary of Anderson’s life insurance policy under the Federal Employees’ Group Life Insurance Act (FEGLI), which included both standard and accidental death benefits.After Anderson’s death, Finney submitted claims for both types of benefits to Metropolitan Life Insurance Company (MetLife), the insurer. MetLife paid the standard life insurance benefit but denied the additional accidental death benefit. The denial was based on two grounds: that Anderson’s death was not “accidental” within the policy’s meaning, and that her death was “contributed to by” her pre-existing physical illness, thus falling under an exclusion in the policy. Finney filed suit in the United States District Court for the Northern District of Alabama, arguing that the denial breached the insurance contract. Both parties moved for judgment as a matter of law. The district court ruled in favor of MetLife, finding that the denial was reasonable under the policy’s physical illness exclusion.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The Eleventh Circuit held that MetLife’s decision to deny accidental death benefits was not arbitrary or capricious, as the policy clearly excluded coverage when a physical illness contributed to the insured’s death. The court concluded that Anderson’s pre-existing lung disease contributed to her death and that MetLife’s denial was reasonable under the terms of the insurance contract. View "Finney v. Metropolitan Life Insurance Company" on Justia Law

A.B., a minor, was sexually exploited by her mother and David Barrow when she was ten years old. In February 2018, A.B. filed a lawsuit against Barrow in Alabama state court for invasion of privacy. After a bench trial in April 2022, the court found in favor of A.B., awarding her $4 million in compensatory damages and $6 million in punitive damages. During related litigation, A.B.’s attorney learned that Barrow was likely insured by Nationwide Mutual Insurance Company, and in November 2018, served a subpoena on Nationwide, which produced Barrow’s umbrella liability insurance policy covering invasion of privacy claims.Nationwide removed the subsequent coverage action filed by A.B. under Alabama’s Direct Action Statute to the United States District Court for the Northern District of Alabama. The district court granted summary judgment for Nationwide, holding that neither Barrow nor A.B. notified Nationwide of the potential duty to indemnify “as soon as reasonably possible,” as required by the policy. The district court emphasized the 58-month delay between Barrow’s conduct and Nationwide receiving notice, and found that no reasonable excuse for the delay was offered by Barrow.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that, under Alabama law and the terms of the policy, notice may be provided by the insured or someone on the insured’s behalf, including the injured party. However, the timeliness of notice is judged from the insured’s perspective. Because Barrow did not give notice to Nationwide within a reasonable time and offered no excuse for the delay, coverage was barred. The court rejected arguments that notice by A.B. could reset the timing requirement and concluded that summary judgment for Nationwide was proper. View "A. B. v. Barrow" on Justia Law

The case involves a Florida-based title insurer that suffered significant financial setbacks, prompting a series of business restructurings and asset transfers. In 2009, the company entered a joint venture with another title insurance group, forming a new entity to handle certain business functions. Over subsequent years, the original company retained substantial assets and continued operations, but further financial decline led to a 2015 agreement in which it transferred assets and liabilities to its business partner, in exchange for the assumption of its policy liabilities. The Florida insurance regulator scrutinized and ultimately approved the transaction after requiring additional commitments from the acquiring party.The United States Bankruptcy Court for the Middle District of Florida later oversaw the company’s Chapter 11 proceedings. The appointed Creditor Trustee brought an adversary proceeding against the acquiring parties and related entities, alleging that the asset transfer constituted a fraudulent transfer under federal bankruptcy law and Florida statutes, and sought to impose successor liability and alter ego claims. The bankruptcy court held a bench trial, excluding portions of the Trustee’s expert valuation as unreliable, and found that the company had received reasonably equivalent value in the transaction. The court also rejected the successor liability and alter ego theories, finding insufficient evidence of continuity of ownership, improper purpose, or harm to creditors.The United States District Court for the Middle District of Florida affirmed the bankruptcy court’s rulings. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the record and affirmed the district court’s order. The Eleventh Circuit held that the bankruptcy court did not err in excluding the Trustee’s expert, that the asset transfer was for reasonably equivalent value and not fraudulent, and that the successor liability and alter ego claims failed for lack of evidence and legal sufficiency. View "Stermer v. Old Republic National Title Insurance Company" on Justia Law

Cheriese Johnson began experiencing a range of symptoms, including coughing and pain in her hands and feet, prior to her employment in July 2016 with The William Carter Company. She purchased a long-term disability insurance policy from Reliance Standard that became effective in October 2016. During the three months before her coverage began, Johnson sought medical care for various symptoms and received several diagnoses, but not scleroderma. In early 2017, after her policy was active, she was diagnosed with scleroderma—a rare autoimmune disease—following a lung biopsy. Johnson then filed a claim for long-term disability benefits, which Reliance Standard denied, arguing her disability was caused by a preexisting condition for which she had received treatment during the policy’s lookback period.After her claim was denied and her appeal was unsuccessful, Johnson sued Reliance Standard in the United States District Court for the Northern District of Georgia under the Employee Retirement Income Security Act (ERISA). She moved for judgment on the administrative record, while Reliance Standard sought summary judgment. The district court granted summary judgment to Reliance Standard, finding its decision to deny benefits was correct under the terms of the policy.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the district court’s judgment. Applying ERISA’s interpretive framework and reviewing the plan administrator’s decision de novo, the Eleventh Circuit held that Reliance Standard’s interpretation of the policy was both incorrect and unreasonable. The court concluded that Johnson had not received medical treatment “for” scleroderma during the lookback period because neither she nor her doctors suspected or intended to treat that specific condition at that time. The court found that Reliance Standard’s interpretation was arbitrary and capricious, and remanded for further proceedings consistent with its opinion. View "Johnson v. Reliance Standard Life Insurance Company" on Justia Law