American Alternative Insurance Corporation v. Legacy International

CourtDistrict Court, W.D. Virginia
DecidedSeptember 30, 2024
Docket6:22-cv-00059
StatusUnknown

This text of American Alternative Insurance Corporation v. Legacy International (American Alternative Insurance Corporation v. Legacy International) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Alternative Insurance Corporation v. Legacy International, (W.D. Va. 2024).

Opinion

VLERROS VIPIGe Uo. Vol. Ut AT LYNCHBURG, VA FILED UNITED STATES DISTRICT COURT 9/30/2024 WESTERN DISTRICT OF VIRGINIA By. CARMA Anos LYNCHBURG DIVISION DEPUTY CLERK AMERICAN ALTERNATIVE INSURANCE CORPORATION, CASE NO. 6:22-cv-00059 Plaintiff, MEMORANDUM OPINION v. LEGACY INTERNATIONAL, e¢ al., JUDGE NORMAN K. Moon Defendants. American Alternative Insurance Corporation (“AAIC”) seeks a declaration that it owes no duty to defend or indemnify its insureds, Legacy International and World Community (“the Charities”), in an underlying state tort case pending in Bedford County Circuit Court. The Court assumes the parties’ familiarity with the facts and procedural posture which were set forth in detail in the Court’s December 6, 2023 Memorandum Opinion. Dkt. 39. No real dispute exists between the parties regarding the relevant facts or background. The parties have therefore filed cross motions for judgment on the pleadings pursuant to Fed. R. Civ. P. 12(c) ona single issue: whether under the “eight corners rule,” AAIC has a duty to defend the Charities in the underlying state court tort case. The Court determines that because the underlying complaint sufficiently alleges counts for negligent supervision and retention, AAIC has a duty to defend the Charities.

Standard of Review A party may move for judgment on the pleadings after the pleadings are closed, but early enough so as not to delay trial. Fed. R. Civ. P. 12(c). “A Rule 12(c) motion is designed to provide a means of disposing of cases when the material facts are not in dispute between the

parties and a judgment on the merits can be achieved by focusing on the content of the competing pleadings, exhibits thereto, matters incorporated by reference in the pleadings, whatever is central or integral to the claim for relief or defense, and any facts of which the district court will take judicial notice.” Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure, § 1006 (3d ed. 1998); see Jones v. Penn Nat. Ins. Co., 835 F. Supp. 2d 89, 93

(W.D.N.C. 2011) (citing A.S. Abell Co. v. Baltimore Typographical Union No. 12, 338 F.2d 190, 193 (4th Cir.1964)). The standard for Rule 12(c) motions is the same as for motions made pursuant to Rule 12(b)(6). Burbach Broadcasting Co. of Delaware v. Elkins Radio Corp., 278 F.3d 401, 405–06 (4th Cir. 2002). As with a motion to dismiss pursuant to Fed R. Civ. P. 12(b)(6), the Court in evaluating a Rule 12(c) motion “does not resolve contests surrounding the facts . . . or the applicability of defenses.” Republican Party of N.C. v. Martin, 980 F.2d 943, 952 (4th Cir. 1992); Hebert Abstract Co. v. Touchstone Properties, Ltd., 914 F.2d 74, 76 (5th Cir. 1990). Analysis

Virginia law governs this diversity suit, and in determining whether a duty to defend exists, Virginia courts apply the “eight corners rule” by comparing the "four corners" of the underlying complaint to the "four corners" of the policy. AES Corp. v. Steadfast Ins. Co., 283 Va. 609, 725 S.E.2d 532, 535 (Va. 2012); CACI Intern., Inc. v. St. Paul Fire and Marine Ins. Co., 566 F.3d 150, 155 (4th Cir. 2009). In examining the four corners of the underlying complaint, the Court need only decide whether the allegations, if proved, would bring the factual scenario within the scope of coverage or an exclusion. Penn-Am. Ins. Co. v. Coffey, 368 F.3d 409, 413 (4th Cir. 2004). Virginia courts interpret insurance policies in accordance with the intention of the parties, giving clear and unambiguous language its plain and ordinary meaning. Fed. Hill Homeowners Ass’n, Inc. v. Cmty. Ass’n Underwriters of Am., 384 F. App’x 209, 212 (4th Cir. 2010). If an ambiguity exists, the court construes it against the insurer and liberally in favor of the insured. Id. An insurer’s duty to defend is broader than its obligation to pay and arises whenever the underlying complaint alleges facts and circumstances, some of which would, if proved, fall within the risk covered by the policy. Virginia Elec. & Power Co. v. Northbrook

Prop. & Cas. Ins. Co., 252 Va. 265, 268, 475 S.E.2d 264, 265 (1996). AAIC argues that M.B.’s “bodily injury” was not caused by an “occurrence” under the terms of the policy, focusing on Rash’s intentional abuse of M.B. Dkt 43 at 10. AAIC states the law clearly: “[a]n intentional act is neither an ‘occurrence’ nor an ‘accident’ and . . . is not covered by the standard [CGL] policy.” Id. (quoting AES Corp., 725 S.E.2d at 536). Counts IV (Vicarious Liability) and IX (Vicarious Liability Under New York Law) of the underlying complaint are based on the Charities’ vicarious liability for Rash’s intentional acts. As such, these allegations fall outside of the definition of an occurrence and are not covered by the policy. However, the allegations in Counts II, III, V, VII and VIII sound in negligence. In those

counts, M.B. claims that the Charities were negligent in caring for, supervising and protecting her (Counts II, III and VIII) and in retaining Rash (Counts V and VII). Dkt. 1-1. The Fourth Circuit has distinguished allegations of a principal’s vicarious liability for its agent’s intentional torts as M.B. has alleged in Counts IV and IX, which do not constitute an “occurrence,” from assertions that the principal was liable for the agent’s intentional act due to its negligent failure to supervise. Liberty Univ., Inc. v. Citizens Ins. Co. of Am., 792 F.3d 520, 530 (4th Cir. 2015) (discussing IFCO Syst. of N. Amer. Inc. v. Am. Home Assurance Co., 502 F. App’x 342 (4th Cir. 2013) (unpublished)). In Liberty Univ., the Court cited several illustrative cases: Pac. Ins. Co. v. Catholic Bishop of Spokane, 450 F. Supp. 2d 1186, 1202 (E.D. Wash. 2006) (rejecting insurer's argument that the alleged sexual abuse was not a covered "accident" because insurer "disregard[ed] the fact that the claims against the diocese [were] based upon alleged negligent hiring, supervision, and retention, not an intentional wrong of direct sexual abuse"); King v. Dallas Fire Ins. Co., 85 S.W.3d 185, 188-92 (Tx. 2002) (finding duty to defend because insured was sued for intentional torts under a theory of respondeat superior and for negligence and

because the "employer's alleged negligent hiring, training, and supervision constitute[d] an 'occurrence' under the terms of the insurance policy although the injury was directly caused by the employee's intentional conduct'"); Unigard Mut. Ins. Co. v. Spokane Sch. Dist. No. 81, 20 Wn. App. 261,

Related

Penn-America Insurance Company v. Gregory Coffey
368 F.3d 409 (Fourth Circuit, 2004)
AES CORP. v. Steadfast Ins. Co.
725 S.E.2d 532 (Supreme Court of Virginia, 2012)
S. F. v. West American Insurance
463 S.E.2d 450 (Supreme Court of Virginia, 1995)
Unigard Mutual Insurance v. Spokane School District No. 81
579 P.2d 1015 (Court of Appeals of Washington, 1978)
King v. Dallas Fire Insurance Co.
85 S.W.3d 185 (Texas Supreme Court, 2002)
Pacific Ins. Co. v. Catholic Bishop of Spokane
450 F. Supp. 2d 1186 (E.D. Washington, 2006)
Jones v. Penn National Insurance
835 F. Supp. 2d 89 (W.D. North Carolina, 2011)
Republican Party of North Carolina v. Martin
980 F.2d 943 (Fourth Circuit, 1992)

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American Alternative Insurance Corporation v. Legacy International, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-alternative-insurance-corporation-v-legacy-international-vawd-2024.