American Casualty Company of Reading, Pennsylvania v. Reese

CourtDistrict Court, D. Delaware
DecidedNovember 4, 2022
Docket1:22-cv-00504
StatusUnknown

This text of American Casualty Company of Reading, Pennsylvania v. Reese (American Casualty Company of Reading, Pennsylvania v. Reese) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Casualty Company of Reading, Pennsylvania v. Reese, (D. Del. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

AMERICAN CASUALTY COMPANY : CIVIL ACTION OF READING, PENNSYVANIA : : v. : NO. 22-504-MAK : ALLEN REESE :

MEMORANDUM KEARNEY, J. November 4, 2022 A behavior therapist twice plead guilty to sexually abusing or assaulting a young man with autism resulting in the behavior therapist’s present incarceration. The young man’s mother then sued the behavior therapist for damages on her son’s behalf. The behavior therapist had earlier purchased a healthcare provider’s personal liability insurance policy to provide him a defense and indemnity for workplace claims. The insurer is providing a defense under a reservation of rights. The therapist is challenging his guilty plea in the criminal courts. The insurer now asks us to declare it has no duty to further defend or indemnify based on the behavior therapist’s earlier guilty pleas barring him from claiming no sexual assault in the civil case, its policy does not apply to the boy’s claims, and the policy’s exclusions otherwise bar coverage. We disagree with the insurer as to the collateral estoppel effect of these guilty pleas now being challenged in post-conviction proceedings. We also find the policy applies to the behavior therapist’s conduct in his alleged workspace. But the insurer is correct the behavior therapist agreed to exclude insurance coverage for claims of sexual misconduct, regardless of findings or appeals. We enter summary judgment in favor of the insurer and declare there is no duty to further defend or provide indemnity to the therapist based on the allegations now pending against the behavior therapist. I. Undisputed material facts1 Allen Reese formerly worked as a behavior therapist for Delaware Guidance Services for Children and Youth.2 He interacted with minor L.N. through his employment. L.N. is a young man with autism. The Attorney General for the State of Delaware charged Mr. Reese with sexually

abusing L.N. The Maryland State Attorney for Worcester County also charged Mr. Reese with sexually abusing L.N. Mr. Reese plead guilty to two counts of Sexual Abuse of a Child by a Person in a Position of Trust in Delaware state court on July 23, 2021 and the Sexual Abuse of a Minor in Maryland state court on October 28, 2021.3 The Delaware state court judge sentenced Mr. Reese to twenty- five years’ incarceration.4 Mr. Reese also received a twenty-five year sentence from the Maryland state court judge.5 Mr. Reese moved for post-conviction relief after pleading guilty in the Delaware criminal case.6 Mr. Reese also plans to move for post-conviction relief in the Maryland criminal case.7 Mr. Reese is currently serving his sentence at the Sussex Correctional Institute in Georgetown,

Delaware.8 L.N. is the alleged victim of Mr. Reese’s conduct in both the Maryland and Delaware criminal cases. L.N.’s mother sued Mr. Reese on April 9, 2021 in Delaware Superior Court for compensatory and punitive damages arising from Mr. Reese’s admitted pleas of sexual assault of L.N on November 26, 2019 in Maryland and on November 27, 2019 in Delaware.9 L.N.’s mother alleges Mr. Reese “act[ed] as an agent and employee” of Delaware Guidance Services for Children and Youth when he committed the alleged sexual assaults because the Delaware Guidance Services for Children and Youth assigned Mr. Reese “to be the counselor and responsible for the care” of her autistic son L.N.10 L.N.’s mother does not plead a claim other than for personal injuries arising from the sexual assault against Mr. Reese.11 Mr. Reese’s Professional Liability and Workplace Coverage insurance. Mr. Reese purchased a Healthcare Providers Professional Liability Insurance Policy from American Casualty Company of Reading, Pennsylvania in connection with his employment as a behavior therapist.12 American Casualty provides $1 million in coverage for each covered claim

and $3 million for all covered claims combined.13 Mr. Reese notified American Casualty of L.N.’s underlying civil lawsuit against him. The insurer agreed to provide a defense to Mr. Reese subject to a complete reservation of rights in letters dated July 2, 2021 and July 6, 2021.14 American Casualty preserved the ability to withdraw representation under its Policy exclusions.15 Mr. Reese seeks to invoke the duty to defend and indemnify in two portions of his insurance policy: Professional Liability Coverage and Workplace Liability Coverage.16 The Policy’s Professional Liability Coverage requires American Casualty to defend Mr. Reese and pay for license protection, the amount of liability owed, and claim expenses.17 The Policy’s Professional Liability Coverage contains several exclusions including: a sexual

misconduct exclusion,18 a willful violation of law exclusion,19 a punitive damages exclusion,20 and an expected or intended injury exclusion.21 The Policy’s Workplace Liability Coverage requires American Casualty to provide a defense and pay for liability for a claim of injury caused by an occurrence at the workplace.22 The Workplace Liability Coverage, like the Professional Liability Coverage, also contains several exclusions including a sexual misconduct exclusion,23 a professional services exclusion,24 a willful violation of law exclusion,25 a punitive damages exclusion,26 and an expected or intended injury exclusion.27 Both coverages limit the amount of coverage through a sexual misconduct sublimit.28 The sexual misconduct sublimit limits the amount American Casualty will pay in a covered sexual misconduct claim to $25,000.29 The $25,000 sublimit applies to all claims combined under both the Workplace Liability Coverage and the Professional Liability Coverage.30 American Casualty caps its exposure if the “sexual misconduct has not been determined to have occurred by any . . . court ruling . . . whether appealed or not.”31

II. Analysis American Casualty seeks a declaratory judgment it has no duty to defend or indemnify Mr. Reese and is entitled to immediately withdraw from defending Mr. Reese in the underlying civil lawsuit.32 American Casualty argues it has no duty to defend or indemnify Mr. Reese in the underlying civil lawsuit under the Professional Liability Coverage or the Workplace Liability Coverage. Even if the Policy affords coverage, American Casualty contends the sexual misconduct exclusions, professional services exclusion, willful violation of law exclusions, punitive damages exclusions, and expected or intended injury exclusions preclude coverage.33 If we find American Casualty has a duty to defend or indemnify Mr. Reese in the underlying civil lawsuit, American

Casualty asks we declare American Casualty’s maximum limit of liability under the Policy is the sexual misconduct aggregate sublimit of $25,000, and after payment of the sublimit, American Casualty’s duty to defend or settle on behalf of Mr. Reese in the underlying civil lawsuit ends.34 American Casualty now moves for summary judgment.35 American Casualty asks we declare American Casualty has no obligation to defend or indemnify Mr. Reese in connection with the underlying civil lawsuit.36 American Casualty argues the interpretation of the policy language is an issue of law and the doctrine of issue preclusion bars Mr. Reese from arguing he did not commit the actions necessary to his guilty pleas.37 American Casualty claims it has no duty to defend or indemnify Mr. Reese under the Policy’s Professional Liability Coverage because the coverage does not apply, and even if it did, the sexual misconduct exclusion, willful violation of law exclusion, punitive damages exclusion, and expected or intended injury exclusion prevent coverage.38 American Casualty also argues it has no duty to defend or indemnify Mr. Reese under the Policy’s Workplace Liability Coverage because the coverage does not apply, and even if it did,

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American Casualty Company of Reading, Pennsylvania v. Reese, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-casualty-company-of-reading-pennsylvania-v-reese-ded-2022.