NOT RECOMMENDED FOR PUBLICATION File Name: 25a0518n.06
No. 24-1492
UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Nov 04, 2025 AMERISURE MUTUAL INSURANCE ) KELLY L. STEPHENS, Clerk COMPANY, fka Michigan Mutual Insurance ) ) Company, ) Plaintiff-Appellant, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF MICHIGAN SWISS REINSURANCE AMERICA ) CORPORATION, ) OPINION Defendant-Appellee. ) ) )
Before: MOORE, GRIFFIN, and RITZ, Circuit Judges.
GRIFFIN, Circuit Judge.
This appeal concerns whether collateral estoppel precludes plaintiff Amerisure Mutual
Insurance Company from litigating an issue in federal court that was previously decided against it
in an arbitration between Amerisure and one of its reinsurance providers, Allstate. Now, under
identical reinsurance policy provisions at issue in that arbitration, Amerisure seeks a declaratory
judgment to recover defense costs from a different reinsurance provider, defendant Swiss
Reinsurance America Corporation (“Swiss Re”), arguing that it is not estopped from litigating the
same issue because Swiss Re was not a party to the arbitration. The district court disagreed and
granted summary judgment in Swiss Re’s favor on collateral-estoppel grounds. We affirm. No. 24-1492, Amerisure Mut. Ins. Co. v. Swiss Reinsurance Am. Corp.
I.
From 1979 to 1981, Amerisure issued several primary and umbrella insurance policies to
Armstrong International, a manufacturer of building materials. To help cover these multi-million-
dollar policies, Amerisure purchased reinsurance (insurance for insurance companies) from several
reinsurance providers, including Swiss Re and non-party Allstate, under reinsurance contracts
known as facultative certificates. See Allstate Ins. Co. v. Amerisure Mut. Ins. Co., 2020
WL 1445615, at *1 (N.D. Ill. Mar. 25, 2020). Pursuant to the facultative certificates between
Swiss Re and Amerisure, Swiss Re must cover any liability owed by Amerisure to Armstrong up
to the umbrella policy limits.
Over several decades, thousands of claimants sued Armstrong, alleging that it
manufactured, distributed, or sold building materials that contained asbestos. Under its primary
insurance policies with Armstrong, Amerisure paid for Armstrong’s defense costs and indemnified
it for its losses. When Armstrong exhausted the limits of these primary policies, it requested
additional defense costs under its umbrella policies with Amerisure. Notably, Amerisure agreed
to continue paying Armstrong’s defense costs in addition to—as opposed to within—the umbrella
policy limits.
Amerisure sought reimbursement from its reinsurance providers for the defense costs it
had paid towards the Armstrong asbestos litigation. Swiss Re paid millions of dollars in
reinsurance, but only up to the umbrella policy limit of $3,500,000. Swiss Re—and the other
reinsurers, like Allstate—refused to reimburse defense costs that Amerisure paid in addition to the
policy limits because the umbrella policies did not contractually obligate Amerisure to pay these
costs. Those costs, the reinsurers argued, are therefore not covered by the facultative certificates.
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Prior to this litigation, Allstate initiated arbitration proceedings with Amerisure to resolve
the defense-cost dispute. Id. After eighteen months of arbitration, which included discovery,
briefing, and hearings, the arbitration panel unanimously decided that the umbrella policies only
required Amerisure to pay defense costs within the umbrella policy limits. Allstate was therefore
not liable for Amerisure’s payment of defense costs beyond those limits. Nonetheless, shortly
after the arbitration panel issued its final decision, Amerisure sought and received judicial
confirmation of the award in federal court because it considered the award favorable overall. Id.
at *3, *7.
Years later, Amerisure filed a complaint against Swiss Re, requesting a declaratory
judgment that would allow it to recover defense costs from Swiss Re based on the same umbrella
policies that were at issue in the Allstate arbitration. The stakes are high: Amerisure has incurred
millions of dollars of defense costs from Armstrong’s asbestos litigation, well beyond the umbrella
policy limits, and it anticipates more lawsuits against Armstrong in the future.
Amerisure and Swiss Re each moved for summary judgment. In its motion, Amerisure
made the same arguments that it made against Allstate during arbitration to support its position
that its umbrella policies with Swiss Re, which contain identical provisions to those at issue in the
Allstate arbitration, obligate Swiss Re to reimburse Amerisure for any defense costs that
Amerisure paid in addition to the umbrella policy limits. For its part, Swiss Re argued that
collateral estoppel precluded Amerisure from litigating the defense-cost issue again because it was
fully, fairly, and finally decided in arbitration, in Allstate’s favor and against Amerisure. The
district court granted summary judgment in Swiss Re’s favor, holding that Amerisure was
collaterally estopped from relitigating the defense-cost issue. Amerisure timely appealed.
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II.
We review de novo a district court’s resolution of cross-motions for summary judgment
and its application of collateral estoppel. See Stryker Corp. v. Nat’l Union Fire Ins. Co., 681 F.3d
819, 823 (6th Cir. 2012) (de novo review of summary judgment in a declaratory-relief suit); In re
Calvert, 105 F.3d 315, 317 (6th Cir. 1997) (de novo review of collateral-estoppel determination).
“Summary judgment is appropriate if, viewing the evidence and drawing all reasonable inferences
in the light most favorable to the nonmoving party,” there is “no genuine issue as to any material
fact” and the movant is entitled to judgment as a matter of law. CMACO Auto. Sys., Inc. v.
Wanxiang Am. Corp., 589 F.3d. 235, 241–42 (6th Cir. 2009) (citation omitted); see Fed. R. Civ.
P. 56(a).
III.
Collateral estoppel, also known as issue preclusion, prevents a party from “raising an
argument that [it] already fully litigated in an earlier legal proceeding.” See Anderson v. City of
Blue Ash, 798 F.3d 338, 350 (6th Cir. 2015). It is an equitable doctrine that applies in the interest
of fairness and judicial economy and can be set aside when its “application would contravene an
overriding public policy or result in manifest injustice.” Harrington v. Vandalia-Butler Bd. of Ed.,
649 F.2d 434, 439 (6th Cir. 1981).
To decide whether collateral estoppel applies, we look to several elements. These elements
are derived from state or federal law, depending on which applies. Typically, federal courts “look
to the common law or to the policies supporting res judicata and collateral estoppel in assessing
the preclusive effect of decisions of other federal courts.” Hamilton’s Bogarts, Inc. v. Michigan,
501 F.3d 644, 650 (6th Cir. 2007) (quoting Allen v. McCurry, 449 U.S. 90, 96 (1980)). And
Congress requires federal courts to “give the same preclusive effect to a state-court judgment as
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that judgment receives in the rendering state” by applying state law. Abbott v. Michigan, 474 F.3d
324, 330 (6th Cir. 2007) (citing 28 U.S.C. § 1738). Under Michigan law, collateral estoppel
generally requires three elements to “be satisfied: (1) [an issue] ‘essential to the judgment must
have been actually litigated and determined by a valid and final judgment’; (2) ‘the same parties
must have had a full [and fair] opportunity to litigate the issue’; and (3) ‘there must be mutuality
of estoppel,’” unless estoppel is being asserted defensively. W.J. O’Neil Co. v. Shepley, Bulfinch,
Richardson & Abbott, Inc., 700 F. App’x 484, 490 (6th Cir. 2017) (quoting Monat v. State Farm
Ins. Co., 677 N.W.2d 843, 845–46 (Mich. 2004)). Under federal law, the elements of collateral
estoppel are stated differently, though they may be treated substantively the same for purposes of
this case. See Hammer v. I.N.S., 195 F.3d 836, 840 (6th Cir. 1999) (outlining federal estoppel
factors). But at issue here is an arbitration award—not a judgment from either federal or state
court—and we have not yet decided the question whether federal or state law applies to issues
concerning the preclusive effect of arbitration awards in federal court. See W.J. O’Neil Co., 700
F. App’x at 489–90 (“[T]he question of whether to apply federal or Michigan preclusion law to
evaluate the binding nature of an arbitration proceeding is less than clear.”).
We need not resolve the novel choice-of-law question in this case, however. Although the
parties agree that either Michigan or federal law governs, they do not argue that one applies over
the other. Instead, they recognize, as did the district court, that the elements of collateral estoppel
under federal and Michigan law are “substantially the same,” so they apply both. Compare
Hamilton’s Bogarts, 501 F.3d at 650 (federal elements), with Monat, 677 N.W.2d at 845–46
(Michigan elements). Cf. CenTra, Inc. v. Estrin, 538 F.3d 402, 409 (6th Cir. 2008) (recognizing
a “false conflict” and thus declining to resolve the choice-of-law question where Michigan law is
“consistent with . . . other possible sources of law”). We therefore apply both state and federal
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law to analyze the elements of collateral estoppel that Amerisure contests: whether the relevant
issue was actually litigated in arbitration, whether Amerisure had a full and fair opportunity to
litigate the issue, and mutuality of estoppel.
A.
First, the relevant issue—whether Amerisure’s reinsurers must reimburse it for defense
costs it paid to Armstrong over the umbrella policy limits—was raised and actually litigated during
the Allstate arbitration. The arbitration panel decided this issue against Amerisure, explaining that
“[d]efense costs incurred by Amerisure are payable within limits . . . and covered under the
respective facultative certificates until the amount of ‘Reinsurance Accepted’ under each
facultative certificate has been met.” Beyond this, the panel did not detail its reasons for ruling
against Amerisure on the defense-cost issue.
Amerisure insists that a proper interpretation of the umbrella policies’ drop-down
provision, which states that the policy “continue[s] in force as underlying insurance in the event
of exhaustion,” is an issue that would decide the dispute in its favor but that was never “decided
or even addressed in connection with the Allstate arbitration.”1 Although Amerisure admits that
it presented its drop-down-provision argument before the arbitration panel, Amerisure contends
that the arbitration panel did not specifically address this argument in its interim or final award.
A final arbitration award, however, “need not explicitly have addressed the issue [for it] to
be precluded.” People v. Gates, 452 N.W.2d 627, 631 (Mich. 1990) (applying the same reasoning
where the first proceeding was a criminal trial that resulted in a general jury verdict). Although a
cursory arbitration award, like a general jury verdict, “may make the determination of what issues
1 According to Amerisure, the drop-down provision required it to pay for Armstrong’s defense costs in addition to the umbrella policy limits and therefore requires Swiss Re to reimburse it for these defense costs. -6- No. 24-1492, Amerisure Mut. Ins. Co. v. Swiss Reinsurance Am. Corp.
have been decided problematic, . . . it does not automatically bar the application of collateral
estoppel.” Id. So long as the arbitration record supports the conclusion that the arbitration panel’s
decision necessarily decided an issue, we may apply collateral estoppel. See id. at 631–32; see
also Ashe v. Swenson, 397 U.S. 436, 444 (1970) (explaining that determining the preclusive effect
of a prior judgment requires courts to “examine the record of a prior proceeding, taking into
account the pleadings, evidence, charge, and other relevant matter, and conclude whether a rational
jury could have grounded its verdict upon an issue other than that which the defendant seeks to
foreclose from consideration” (citation omitted)); Dowling v. United States, 493 U.S. 342, 350
(1990) (same).
The arbitration record supports such a conclusion here. In its pre-hearing brief submitted
to the arbitration panel, Amerisure argued that the drop-down provision required it to pay
Armstrong’s defense costs in addition to the umbrella policy limits. Amerisure also raised the
drop-down-provision argument throughout the arbitration hearing: in its opening statement to the
arbitration panel, during witness examinations, and during its closing argument. Included in its
briefs and hearing arguments were citations to and analyses of cases from various jurisdictions
where courts interpreted similar drop-down provisions. Although the arbitration panel did not
expressly address the drop-down provision, it necessarily decided that the drop-down provision
does not require Amerisure to cover Armstrong’s defense costs in addition to the policy limits
because it decided the defense-cost issue against Amerisure.
Moreover, even if the arbitration panel overlooked the drop-down argument because, as
Amerisure suggests, it did not “focus” on that argument during arbitration, Amerisure is not
entitled to rejigger its arguments in support of the same issue. Amerisure’s strategic failure to
focus on what it now thinks is a stronger argument does not change the fact that the defense-cost
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issue was raised and actually litigated in arbitration. See United States v. United Techs. Corp.,
782 F.3d 718, 728–29 (6th Cir. 2015) (“[I]ssue preclusion does not disappear merely because the
losing party puts on a better case the second time around.”).
Together, the arbitration record and award indicate that the drop-down provision was
necessarily decided against Amerisure. Therefore, the defense-cost issue at the heart of this dispute
was raised and actually litigated in arbitration.
B.
Amerisure also had the opportunity to fully litigate the defense-cost issue during the
arbitration. Because “no one set of facts, no one collection of words or phrases, will provide an
automatic formula for proper rulings on estoppel pleas,” we consider several factors when
determining whether a party had a full and fair opportunity to litigate an issue. See Blonder-
Tongue Lab’ys, Inc. v. Univ. of Ill. Found., 402 U.S. 313, 333–34 (1971). These factors include
whether the party “actively participated in the arbitration hearing,” “enjoyed representation from
counsel,” “presented opening and closing statements,” engaged in discovery, and examined
witnesses. See W.J. O’Neil Co., 700 F. App’x at 492–93; Restatement (Second) of Judgments
§ 84 cmt. c (1982) (“When arbitration affords opportunity for presentation of evidence and
argument substantially similar in form and scope to judicial proceedings, the award should have
the same effect on issues necessarily determined as a judgment has.”). All of these factors were
present in Amerisure’s arbitration with Allstate. See Allstate Ins. Co., 2020 WL 1445615, at *1.
Also included among the factors is whether the party estopped had a right to appeal the
prior adverse decision. Monat, 667 N.W.2d at 847. Amerisure contends that it could not have
obtained judicial review of the arbitration award because the facultative certificates with Allstate
provide that the arbitration panel’s decision “shall be final and binding upon the parties.” But
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Amerisure agreed to an arbitration process that lacked appellate review. See id. (applying
collateral estoppel where the plaintiff voluntarily waived his right to appeal the prior judgment).
Even so, Amerisure, “of course, had an opportunity to appeal the arbitrators’ award by moving to
vacate it.” Cent. Transp., Inc. v. Four Phase Sys., Inc., 936 F.2d 256, 262 (6th Cir. 1991). Under
the Federal Arbitration Act (FAA), “any party to the arbitration” may move to vacate the
arbitration award under several circumstances. See 9 U.S.C. § 10. The Allstate facultative
certificates did not override Amerisure’s opportunity to move to vacate the award under the FAA.
Rather than move to vacate the award, however, Amerisure moved to confirm it in federal
district court. See Allstate Ins. Co., 2020 WL 1445615, at *1. Amerisure contends that it moved
to confirm the “mixed-bag award” because it “was favorable to Amerisure overall,” as Amerisure
won on several other issues at arbitration. But a party’s strategic decision not to appeal an adverse
ruling and to instead, in Amerisure’s words, “take the bad with the good,” in no way undermines
the preclusive nature of a final and fair adjudication. Just because Amerisure moved to confirm
the award for strategic reasons—despite losing on the defense-cost issue—does not mean that
Amerisure had no opportunity to move to vacate if it believed at least one of the grounds for vacatur
under the FAA was present. See 9 U.S.C. § 10. Amerisure is therefore incorrect that it could not
appeal the decision at all.
Amerisure urges us to hold, as “an issue of first impression,” that the limited opportunities
for appellate review in arbitration make it unfair to give preclusive power to arbitration awards.
We decline to adopt Amerisure’s position. Although “[j]udicial review of arbitration awards is
tightly limited,” Allstate Ins. Co., 2020 WL 1445615, at *3 (citation omitted), we routinely apply
collateral estoppel to arbitration awards, see, e.g., W.J. O’Neil Co., 700 F. App’x at 489–94; Cent.
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Transp., 936 F.2d at 259 (“[[F]ederal courts ordinarily give preclusive effect to arbitrations.”);
Ivery v. United States, 686 F.2d 410, 413–14 (6th Cir. 1982).
Relatedly, Amerisure argues that it did not have a full and fair opportunity to litigate the
issue based on the “differences in the quality or extensiveness of the procedures followed” in
arbitration proceedings and judicial actions. See Monat, 677 N.W.2d at 845 n.2 (quoting
Restatement (Second) of Judgments § 28 (1982)). Amerisure relies on the “honorable
engagement” arbitration clause, which relieves arbitrators “from all judicial formalities” and
allows them to “abstain from following strict rules of law.” But although the Allstate arbitration
may not have been identical to a judicial proceeding in all respects, it was nonetheless
“substantially similar in form and scope to” one. Restatement (Second) of Judgments § 84 cmt. c
(1982) (emphasis added). “Moreover, even [if] the arbitrators were lax in admitting evidence and
were not bound by the Federal Rules of Evidence[,] these liberal procedures [would] not detract
from the basic elements of adjudicatory procedures that the proceedings afforded them.
Furthermore, the [alleged] liberality applied to both parties equally.” Cent. Transp., 936 F.2d at
261 (citation modified). And Amerisure has “not shown that the arbitration process to any extent
was unfair or the decision unreliable.” Id. (citation omitted).
Nor has Amerisure specified “an intervening change in the applicable legal context,” which
is another factor that could indicate the issue was not fully litigated. See Monat, 677 N.W.2d at
845 n.2 (quoting Restatement (Second) of Judgments § 28 (1982)). Amerisure cites no case or
law to support its argument that the legal context has changed since the Allstate arbitration. Indeed,
all the cases cited herein and in the district court’s opinion pre-date the 2019 arbitration. The legal
context surrounding collateral estoppel as it applies to arbitration has been established in federal
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and Michigan state courts for decades and has not changed since Amerisure’s arbitration with
Allstate.
In sum, Amerisure had a full and fair opportunity to litigate the defense-cost issue in
arbitration.
C.
Amerisure next contends that mutuality of estoppel is not present. This element is met
when the party “taking advantage of the earlier adjudication would have been bound by it.” Monat,
677 N.W.2d at 846 (citation omitted). Because Swiss Re was not a party to the Allstate arbitration,
there is no mutuality of estoppel. Nevertheless, the lack of mutuality does not doom Swiss Re’s
assertion of collateral estoppel.
Mutuality of estoppel is not a core element of federal collateral estoppel because it is not
required when estoppel is asserted defensively (i.e., by a defendant against a plaintiff who was a
party in the prior suit). See Blonder-Tongue, 402 U.S. at 329 (“In any lawsuit where a defendant,
because of the mutuality principle, is forced to present a complete defense on the merits to a claim
which the plaintiff has fully litigated and lost in a prior action, there is an arguable misallocation
of resources.”). Nor do federal courts necessarily require mutuality when it is asserted offensively
(i.e., by a plaintiff against a defendant who was a party in the prior suit). See Parklane Hosiery
Co. v. Shore, 439 U.S. 322, 329–31 (1979) (distinguishing between defensive and offensive
collateral estoppel and granting “trial courts broad discretion to determine when [offensive
collateral estoppel] should be applied”). Michigan courts, by contrast, do require mutuality when
it is asserted offensively, see Martin v. Metro. Life Ins. Co., 364 N.W.2d 348, 353–54 (Mich. Ct.
App. 1985), but never when it is asserted defensively, Monat, 677 N.W.2d at 850–51.
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As the district court concluded, Swiss Re asserts collateral estoppel defensively. Indeed,
Swiss Re raises collateral estoppel to defend against Amerisure’s attempt to relitigate the same
defense-cost issue that Amerisure previously raised and lost in arbitration. See, e.g., Ga.-Pac.
Consumer Prods. LP v. Four-U-Packaging, Inc., 701 F.3d 1093, 1098–99 (6th Cir. 2012)
(“Because the defendant in this case is the party invoking issue preclusion, defensive collateral
estoppel, rather than offensive collateral estoppel, applies.”).
Amerisure disagrees and argues that Swiss Re asserts estoppel offensively. Amerisure
emphasizes that it was the defendant in arbitration, so it is not as though it tactically initiated an
action first against Allstate and then against Swiss Re. But the distinction between Amerisure’s
label as the defendant in arbitration and its label as the plaintiff now is immaterial—what matters
is that Amerisure’s argumentative posture in both actions is the same: it argued then and argues
now that it should be reimbursed for defense costs paid beyond the umbrella policy limits. So the
motivation behind collateral estoppel—to prevent a party from relitigating issues that it previously
lost in other proceedings—applies to this proceeding even though Swiss Re is a new party. At
bottom, requiring mutuality in this case would “only encourage[] gamesmanship by [Amerisure],”
Monat, 677 N.W.2d at 851, who could continue to litigate and arbitrate piecemeal actions with its
reinsurers until it obtains a favorable ruling against one of them.
Therefore, the lack of mutuality of estoppel does not preclude us from applying collateral
estoppel.
D.
Accordingly, the elements of collateral estoppel support the district court’s decision to
estop Amerisure from relitigating the defense-cost issue.
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IV.
Amerisure alternatively argues that even if the elements of collateral estoppel are met, it
would be unjust to apply it in this case. But Amerisure’s fairness arguments are repetitive and, for
many of the reasons explained above, do not hold water.
First, Amerisure argues, again, that the honorable-engagement provision in the Amerisure-
Allstate arbitration clause renders collateral estoppel unjust because it allowed the arbitration panel
to apply different legal and evidentiary standards than courts apply. As discussed above, we apply
collateral estoppel to arbitration decisions, despite the different rules and procedures that arbiters
follow. And none of Amerisure’s out-of-circuit cases bind or persuade us to adopt a different rule.
Perhaps we could be persuaded to forgo collateral estoppel if there were “reason to doubt the
quality, extensiveness, or fairness of procedures followed” in an arbitration. Montana v. United
States, 440 U.S. 147, 164 n.11 (1979). But Amerisure does not specify any unfair conduct by the
arbitration panel. Instead, Amerisure would have us adopt a broad rule that any arbitration decision
that resulted from proceedings that did not apply the same rules and procedures that courts apply
cannot have preclusive effect. Again, we decline to adopt such a rule.
Amerisure next argues that collateral estoppel will harm third-party Armstrong because, if
Amerisure cannot collect payment for its defense costs, Amerisure may not be able to afford
Armstrong’s defense costs. And Armstrong, an amicus curiae, asks us to consider how
“Amerisure’s inability to pursue the reimbursement it anticipated to receive from Swiss Re may
chill its desire to support a vigorous defense of Armstrong.” How our decision impacts non-party
Armstrong is irrelevant. Whether Amerisure can afford to pay costs that an arbiter decided it was
not obligated to pay is irrelevant to the question whether collateral estoppel applies. It does, and
any adverse consequences of the arbitration award upon Amerisure or its insureds do not by
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themselves warrant reconsideration of that decision. Otherwise, every party that lost at arbitration
would relitigate the issue.
Additionally—and once again—Amerisure suggests that the “difference in issue and
Amerisure’s focus” on the drop-down provision warrants relitigation of the defense-cost issue.
But for the reasons explained above, it would be inequitable to allow Amerisure a second bite at
the apple simply because it now has a different strategic focus. Parties are bound by the strategy
decisions they make in arbitration as well as in litigation. The arbitration panel ruled against
Amerisure, rejecting all its arguments in support of the defense-cost issue—a decision by which
Amerisure is now bound.
Last, Amerisure gives us the kitchen sink, arguing that the “combination of these factors
renders application of collateral estoppel grossly unfair and does not serve the objectives of the
doctrine.” We disagree. In fact, we find that precluding Amerisure from relitigating the same
issue against Swiss Re does serve one of the essential purposes of the collateral-estoppel doctrine,
which is to “promote[] judicial economy by preventing needless litigation.” See Parklane,
439 U.S. at 326.
V.
For these reasons, we affirm the district court’s judgment.
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