Athene Annuity and Life Company v. Assicurazioni Generali S.P.A.

CourtSuperior Court of Delaware
DecidedApril 9, 2026
DocketN25C-10-250 KMM CCLD
StatusPublished

This text of Athene Annuity and Life Company v. Assicurazioni Generali S.P.A. (Athene Annuity and Life Company v. Assicurazioni Generali S.P.A.) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Athene Annuity and Life Company v. Assicurazioni Generali S.P.A., (Del. Ct. App. 2026).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

ATHENE ANNUITY AND LIFE ) COMPANY, ) ) Plaintiff, ) C.A. No. N25C-10-250 KMM ) (CCLD) v. ) ) ASSICURAZIONI GENERALI S.P.A., ) ) Defendant. )

Date Submitted: February 20, 2026 Date Decided: April 9, 2026

Defendant’s Motion to Dismiss GRANTED in Part, DENIED in Part

MEMORANDUM OPINION

James G. Gorman III, Adam V. Orlacchio, BLANK ROME LLP, Wilmington, Delaware; Helen K. Michael (argued), Kyle P. Brinkman, BLANK ROME LLP, Washington, DC, Attorneys for Plaintiff.

Joseph S. Naylor, SWARTZ CAMPBELL LLC, Wilmington, Delaware; Anthony Merrill (argued), Ryan P. Hogan, SNELL & WILMER, Phoenix, Arizona, Attorneys for Defendant.

Miller, J. I. INTRODUCTION

Assicurazioni Generali S.p.A (“Generali”) is contractually obligated to

defend, or indemnify Athene Annuity and Life Company (“Athene”) for, claims

arising out of ownership of an office building previously owned by Generali.

Generali, in turn, has indemnification rights against the building’s previous owner.

Athene has defended asbestos claims relating to the building.

After Generali chose not to defend the currently pending claim, Athene

assumed the defense. It claims Generali refused to monetarily participate in

settlement negotiations and refused to acknowledge its contractual indemnification

obligations. Athene filed this action asserting four declaratory judgement claims

relating to Generali’s indemnification obligations under the contract and a breach of

contract claim for failing to reimburse Athene for expenses incurred.

Generali filed a Motion to Dismiss asserting the declaratory judgment claims

are not ripe and the contract claim fails to state a claim under Rule 12(b)(6) (the

“Motion”).1

At oral argument on Generali’s Motion, Generali acknowledged its

contractual obligations with respect to two of the four declaratory judgment claims.

So, to the extent there was a dispute regarding Generali’s obligation to cover punitive

1 D.I. 3. 2 damages or that its indemnification obligations are independent of its indemnitor’s,

the Motion is GRANTED on these claims as they are moot.

A dispute is ripe if the material facts are static and it will result in unavoidable

litigation sooner or later. The remaining declaratory judgment claims fall within this

category. The parties dispute whether the contract requires Athene to make a claim

under any applicable insurance policy and have the claim denied (in whole or part)

before Generali’s indemnification obligations are triggered. No matter the outcome

of the pending claim, the dispute over Athene’s insurance claim obligation, if any,

will need to be resolved. Therefore, the Motion is DENIED on these counts.

The contract is clear that Generali must “promptly reimburse[]” Athene for

fees and expenses “as and when incurred.” There is no dispute that Generali has not

reimbursed Athene, but Athene never submitted the fees and expenses to Generali.

Athene cannot sustain a breach of contract claim where Generali was not given an

opportunity to perform. Accordingly, Athene’s breach of contract claim is

DISMISSED for failure to state a claim.

3 II. BACKGROUND

A. The Purchase Agreement

In 2002, Athene’s predecessor2 acquired Business Men’s Assurance Company

of America (“Business Men’s Assurance Company”)3 from Generali’s predecessor -

Generali Finance B.V. 4 through an equity purchase (the “Purchase Agreement”),

which included ownership of a building known as Tower Headquarters. 5 Under the

Purchase Agreement, Generali is obligated to indemnify Athene against

“Liabilit[ies]6 relating to or arising out of the ownership, operation use or occupancy

at any time before, on or after the Closing of the Tower Headquarters (including …

asbestos related claims by Employees, independent contractors, tenants, or any other

Person).” 7

Section 10.2 of the Purchase Agreement provides:

Subject to … Section 10.4 hereof, Seller shall indemnify and hold harmless Buyer, the Company, and their respective successors, permitted assigns, stockholders, controlling Persons, Related Persons and the Representatives of each of them (collectively, the “Buyer Indemnified Persons”) from and against, and shall reimburse Buyer and the Buyer Indemnified Persons for, any and all losses, Liabilities,

2 Liberty Life Insurance Company. 3 Complaint ¶¶ 1-4 (D.I. 1) (“Compl.”). Liberty Life was acquired by Athene Holding Ltd. and Liberty changed its name to Athene Annuity & Life Insurance Company. In October 2024, Athene Annuity & Life Insurance Company merged with its affiliate Athene Annuity and Life Company. 4 Id. ¶¶ 1, 17. 5 Tower Headquarters is Business Men’s Assurance Company’s headquarters building, located in Kansas City, Missouri. Id. ¶ 19. 6 Capitalized terms not otherwise defined herein have the meaning ascribed to them in the Purchase Agreement. 7 Compl. ¶ 18; see also Purchase Agreement § 10.2 (D.I. 1, Ex. A). 4 Actions, deficiencies, expenses (including reasonable costs of investigation and defense and reasonable attorneys’ and accountants’ fees and expenses) or damages of any kind or nature whatsoever, whether or not involving a third party claim (collectively, “Damages”), incurred thereby or caused thereto, directly or indirectly, based on, arising out of, resulting from, relating to, or in connection with . . .: *** (d) Any of the following Liabilities (in each case irrespective of whether or not such Liability is a Liability of any of the Purchased Companies or otherwise): *** (v) any Liability (i) relating to or arising out of the ownership, operation, use or occupancy at any time before, on or after the Closing, of the Tower Headquarters (including Liabilities under related contracts or asbestos related claims by Employees, independent contractors, tenants, or any other Person) . . . 8

Section 10.4 provides that Damages “shall be reduced to the extent of any

amounts actually received by [Athene] from any third party, … pursuant to the terms

of any insurance or reinsurance contracts covering such Damages.” 9

Under Section 10.6, if Athene provides Generali with notice of the

commencement of a Third Party Claim and if Generali does not elect within 20 days

to assume the defense of the claim, Generali

shall be bound by any determination made in such Third Party Claim or any compromise or settlement effected by the [Athene] to which [Generali] has consented, [Athene] shall conduct the defense thereof in good faith, and [Generali] shall be responsible for the reasonable fees and expenses of counsel employed by [Athene], which shall be

8 Purchase Agreement § 10.2 (bold added). 9 Id. § 10.4. 5 promptly reimbursed for any such fees and expenses, as and when incurred. 10

“Liability” means “any debt, liability, commitment or obligation of any kind,

character or nature whatsoever, whether known or unknown, choate or inchoate,

secured or unsecured, accrued, fixed, absolute, contingent or otherwise, and whether

due or to become due.”11 The Purchase Agreement does not address punitive

damages.

B. The Indemnity Dispute

Since the 2002 purchase, Athene has litigated six asbestos claims relating to

Tower Headquarters, the most recent of which is the Barnes12 claim, which seeks

among other recoveries, punitive damages. 13 After a jury returned a verdict in favor

of Athene in October 2024, 14 Ms. Barnes’ appeal remains pending. 15

After Athene notified Generali of the Barnes claim, it elected not to assume

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