Allstate Vehicle and Property Insurance Company v. Ellenwood

CourtDistrict Court, E.D. Michigan
DecidedSeptember 19, 2025
Docket4:24-cv-11992
StatusUnknown

This text of Allstate Vehicle and Property Insurance Company v. Ellenwood (Allstate Vehicle and Property Insurance Company v. Ellenwood) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allstate Vehicle and Property Insurance Company v. Ellenwood, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

ALLSTATE VEHICLE AND PROPERTY INSURANCE COMPANY et al., Plaintiffs, Case No. 24-11992 Honorable Shalina D. Kumar v. Magistrate Judge Anthony P. Patti

DAVID ELLENWOOD et al.,

Defendants.

OPINION AND ORDER GRANTING PLAINTIFFS’ MOTION FOR ENTRY OF DEFAULT JUDGMENT AGAINST DEFENDANTS DAVID ELLENWOOD, DEBORAH ELLENWOOD, AND TIMOTHY ELLENWOOD (ECF NO. 17)

I. INTRODUCTION Plaintiffs Allstate Vehicle and Property Insurance Company and Allstate Fire and Casualty Insurance Company (collectively, “Allstate”) filed this action seeking a declaratory judgment that it owes no duty to defend or indemnify Timothy Ellenwood (the son and resident relative of Allstate’s insureds, David and Deborah Ellenwood (collectively, “Insureds”)) in an action brought against him by Rachel Cook (Individually, and as Personal Representative of the Estate of Michael William Hunter (Deceased)) in Lenawee County Circuit Court (24-7255-NO). ECF No. 1. Page 1 of 7 The underlying lawsuit arises out of an accident that occurred when a snowmobile being operated by Timothy Ellenwood collided with Michael

Hunter’s ice fishing shanty on February 13, 2021. ECF No.1-4. Hunter sustained fatal injuries as a result. Id. Hunter’s wife, Rachel Cook, brought claims of negligence and gross negligence against Timothy Ellenwood. Id. At

the time of the accident, David and Deborah Ellenwood were insured under a homeowners’ policy and an auto policy (collectively, “Policies”) issued by Allstate Vehicle and Property Insurance Company and Allstate Fire and Casualty Insurance Company, respectively. ECF Nos. 1-2, 1-3. These

Policies provided coverage to the Insureds for damages they were legally obligated to pay because of bodily injury or property damage arising from an occurrence covered by the Policies. Id. This coverage for liability includes a

defense with counsel of Allstate’s choice for the Insureds if they were sued for these types of damages. Id. Timothy Ellenwood, the son of the Insureds, was considered a resident relative at the time of the accident. ECF No. 1, PageID.20.

Allstate is currently defending Timothy Ellenwood in the Lenawee County action, subject to a reservation of rights letter. ECF No. 1-5. As it relates to the current action, Allstate maintains that it is not required to

defend or indemnify Timothy Ellenwood in the underlying suit pursuant to the Page 2 of 7 Insureds’ Policies. David, Deborah, and Timothy Ellenwood (collectively, the “Ellenwoods”) have failed to plead or otherwise defend themselves in this

case. On October 10, 2024, Allstate requested that the Clerk enter default against the Ellenwoods pursuant to the Federal Rule of Civil Procedure

55(a). ECF Nos. 13, 14, 15. The Clerk entered default against the Ellenwoods the same day. ECF No. 16. Allstate then moved for default judgment. ECF No. 17. The Court scheduled a hearing on Allstate’s motion for June 11, 2025. The Ellenwoods failed to appear for the hearing or

otherwise respond to Allstate’s motion for default judgment of declaratory relief against them. ECF No. 32. Following the hearing, the Court requested supplemental briefing as to

why it should exercise its discretionary jurisdiction over this declaratory judgment action before rendering a default judgment against the Ellenwoods. ECF No. 34. Allstate timely submitted its supplemental briefing. ECF No. 35. For the following reasons, the Court grants Allstate’s motion for default

judgment. II. ANALYSIS Before the Court can enter a default judgment against parties who

have not appeared in the case, it must determine whether it has jurisdiction Page 3 of 7 over the defendants. Ford Motor Co. v. Cross, 441 F. Supp. 2d 837, 845 (E.D. Mich. 2006). The Declaratory Judgment Act, 28 U.S.C. § 2201, does

not provide an independent basis for jurisdiction. Heydon v. MediaOne of Southeast Mich., Inc., 327 F.3d 466, 470 (6th Cir. 2003). Rather, it provides courts with discretion to fashion a remedy in cases where federal jurisdiction

already exists. Id. In this case, the jurisdiction of the district court to hear Allstate’s declaratory judgment action arises out of diversity jurisdiction pursuant to 28 U.S.C. § 1332. Nevertheless, the Court is “under no compulsion to exercise that

jurisdiction.” Brillhart v. Excess Ins. Co. of Am., 316 U.S. 491, 494 (1942). Courts are to consider the following five factors in deciding whether to exercise their discretionary jurisdiction over declaratory judgment actions:

(1) whether the judgment would settle the controversy; (2) whether the judgment would clarify the legal relations at issue; (3) whether the declaratory remedy is being used merely for the purpose of “procedural fencing” or “to provide an arena for a race to res judicata;” (4) whether the use of a declaratory action would increase the friction between our federal and state courts and improperly encroach on state jurisdiction; and (5) whether there is an alternative remedy that is better or more effective.

United Specialty Ins. Co. v. Cole’s Place, Inc., 936 F.3d 386 (2019) (quoting Grand Trunk W.R.R. Co. v. Consol. Rail Corp., 746 F.2d 323, 326 (6th Cir. 1984)). Page 4 of 7 Allstate asserts that all five factors weigh in favor of the Court exercising jurisdiction. Indeed, Allstate is not a party in the underlying state

court litigation and thus the coverage dispute between it and the Insureds could not be considered under the existing state court action. See Scottsdale Ins. Co. v. Flowers, 513 F.3d 546, 556 (6th Cir. 2008) (the district court

resolved all controversies between the insurer and the insureds because the only dispute between them was the scope of coverage under the insurance policy). The action before the Court would clarify the legal relations and settle the controversy between these parties; thus, factors one and two

support the Court’s exercise of jurisdiction over this matter. A declaratory relief action over an insurance coverage dispute, where the insurer is not a party to the underlying action and which was initiated

after the underlying state court action, does not suggest procedural fencing or a race for res judicata. See id. at 558. “A district court should not deny jurisdiction to a plaintiff who has not done any more than choose the jurisdiction of federal rather than state court.” Id. (quoting State Farm Fire &

Cas. Co. v. Odom, 799 F.2d 247, 250 n.1 (6th Cir. 1986)) (quotation marks omitted). The third factor supports jurisdiction in this Court. Likewise, this Court accepting jurisdiction over this coverage dispute

does not increase friction between federal and state courts. The liability Page 5 of 7 issue presented in the underlying state court action (whether Timothy Ellenwood operated his snowmobile with negligence or gross negligence) is

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