AMCO INSURANCE COMPANY v. AMERICAN FAMILY MUTUAL INSURANCE COMPANY, S.I.

CourtDistrict Court, W.D. Missouri
DecidedMay 26, 2026
Docket6:25-cv-03303
StatusUnknown

This text of AMCO INSURANCE COMPANY v. AMERICAN FAMILY MUTUAL INSURANCE COMPANY, S.I. (AMCO INSURANCE COMPANY v. AMERICAN FAMILY MUTUAL INSURANCE COMPANY, S.I.) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AMCO INSURANCE COMPANY v. AMERICAN FAMILY MUTUAL INSURANCE COMPANY, S.I., (W.D. Mo. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SOUTHERN DIVISION

AMCO INSURANCE COMPANY, ) ) Plaintiff/Counterclaim Defendant, ) ) vs. ) Case No. 6:25-cv-03303-MDH ) AMERICAN FAMILY MUTUAL ) INSURANCE COMPANY, S.I., ) ) Defendant/Counterclaim Plaintiff. )

ORDER

Before the Court is Plaintiff/Counterclaim Defendant AMCO Insurance Company’s (“Plaintiff” or “AMCO”) Motion for Summary Judgment. (Doc. 17). Plaintiff has filed Suggestions in Support (Doc. 18), Defendant/Counterclaim Plaintiff American Family Mutual Insurance Company, S.I. (“Defendant” or “American Family”) has filed Suggestions in Opposition (Doc. 19), and Plaintiff has filed a reply. (Doc. 20). The motion is now ripe for adjudication on the merits. For the reasons stated herein, Plaintiff’s Motion for Summary Judgment is GRANTED. BACKGROUND This case arises from a dispute regarding which insurance coverage is considered the primary coverage for injuries sustained from a fire at an apartment building in Springfield, Missouri. Plaintiff AMCO is an insurance company incorporated, organized, and existing under the laws of the State of Iowa with its principal place of business in the State of Iowa. Defendant American Family is an insurance company incorporated, organized, and existing under the laws of the State of Wisconsin with its principal place of business in the State of Wisconsin. The Plaintiff issued to Lex Group, Inc. (“Lex”) as named insured a commercial general liability insurance policy with effective dates of July 23, 2021, to July 23, 2022 (the “AMCO Policy”). The AMCO Policy provided bodily injury liability coverage with limits of $1,000,000 each occurrence and $2,000,000 general aggregate. The Defendant issued to Viking Apartments as

named insured a commercial general liability insurance policy, with effective dates of June 1, 2022, to June 1, 2023 (the “American Family Policy”). C4 Partners were added to the policy as an additionally named insured. The American Family Policy provides general liability coverage with limits of $1,000,000 each occurrence and $2,000,000 general aggregate. On August 25, 2023, Sarah Hampshire filed a lawsuit in the Circuit Court of Greene County, Missouri alleging injuries sustained during a fire that occurred on July 14, 2022, at an apartment building owned by C4 Partners and managed by Lex. Lex was C4 Partners’ real estate

manager with respect to the apartment building. In December 2023 or early-January 2024, the Defendant assumed the defense of both C4 Partners and Lex in the underlying state lawsuit. The Plaintiff alleges that it was not until February 5, 2025, that the Defendant provided Plaintiff notice of the fire or the underlying lawsuit. The Plaintiff further alleges that the Defendant has taken the position that the American Family Policy applies as excess over the AMCO Policy, as it concerns coverage for Lex with respect to the underlying state lawsuit.

Plaintiff’s Complaint raises one count: Count I - Declaratory Judgment - Excess Coverage. The Plaintiff seeks a declaratory judgment by this Court declaring that American Family Policy affords primary coverage to Lex and that the Defendant has the primary obligation to defend and indemnify Lex in the underlying lawsuit. The Defendant filed a counterclaim asking this Court for a declaratory judgment that the AMCO Policy affords primary coverage to Lex in the underlying lawsuit, and declaring the American Family Policy provides only excess coverage to Lex. Alternatively, the Defendant asks for a declaratory judgment that the American Family Policy and the AMCO Policy apply pro rata.

STANDARD Summary judgment is proper where, viewing the evidence in the light most favorable to the non-moving party, there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a); Reich v. ConAgra, Inc., 987 F.2d 1357, 1359 (8th Cir. 1993). “Where there is no dispute of material fact and reasonable fact finders could not find in favor of the nonmoving party, summary judgment is appropriate.” Quinn v. St. Louis

County, 653 F.3d 745, 750 (8th Cir. 2011). Initially, the moving party bears the burden of demonstrating the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). If the movant meets the initial step, the burden shifts to the nonmoving party to “set forth specific facts showing that there is a genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). To satisfy this burden, the nonmoving party must “do more than simply show there is some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986).

ANALYSIS I. The AMCO and American Family Policies The Plaintiff argues that the American Family Policy’s “other insurance” provision does

not include an excess clause. Instead, the provision in the American Family Policy only contains a pro-rata clause, simply instructing that the Defendant will not be liable for a greater portion of any loss than the American Family Policy’s limit bears to the whole insurance covering the peril involved. Thus, the Plaintiff argues that the American Family Policy affords primary coverage. The Plaintiff further argues that the AMCO Policy, in contrast, contains an “other insurance” provision which instructs that coverage under the AMCO Policy is excess over any other primary insurance available to Lex covering liability for damages arising out of the premises or operations “for which [Lex] has been added as an additional insured.” Plaintiff asserts Lex is not a named

insured on the American Family Policy, but it qualifies as an “insured” under that Policy because it was added pursuant to the “Who Is An Insured” provision, insuring any person or entity acting as C4 Partner’s real estate manager. The Defendant argues that the AMCO Policy is not excess because Lex has not been added as an additional insured to the American Family Policy. The Defendant concedes that Lex was C4 Partners’ Real Estate Manager when the fire occurred. However, the Defendant argues that this is not dispositive, because qualifying as an “insured” under a “Who Is An Insured” provision is not

the same as being “added as an additional insured.” In support, the Defendant argues that Lex’s status as an “insured” under the American Family Policy is limited to its role as C4 Partners’ real estate manager; it was never affirmatively “added as an additional insured” such as by endorsement, in a contract that requires Lex to be an “additional insured”, or other specific designation. The Defendant argues that unless that condition is satisfied, Plaintiff retains its primary insurer obligations according to its policy’s express terms.

The parties do not dispute the provisions of the policies as noted below. The AMCO Policy states: SECTION IV - COMMERICAL GENERAL LIABILITY CONDITIONS … 4. Other Insurance If other valid and collectible insurance is available to the insured for a loss we cover under Coverages A or B of this Coverage Part, our obligations are limited as follows: a. Primary Insurance This insurance is primary except when Paragraph b. below applies.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Quinn v. St. Louis County
653 F.3d 745 (Eighth Circuit, 2011)
Dibben v. Shelter Insurance Co.
261 S.W.3d 553 (Missouri Court of Appeals, 2008)
Adam Dutton v. American Family Mutual Insurance Company
454 S.W.3d 319 (Supreme Court of Missouri, 2015)
Leslie Seaton v. Shelter Mutual Insurance Company
574 S.W.3d 245 (Supreme Court of Missouri, 2019)

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AMCO INSURANCE COMPANY v. AMERICAN FAMILY MUTUAL INSURANCE COMPANY, S.I., Counsel Stack Legal Research, https://law.counselstack.com/opinion/amco-insurance-company-v-american-family-mutual-insurance-company-si-mowd-2026.