Ballentine Express Corp. v. EAN Holdings, LLC

CourtCourt of Appeals for the Sixth Circuit
DecidedJuly 24, 2024
Docket23-5226
StatusUnpublished

This text of Ballentine Express Corp. v. EAN Holdings, LLC (Ballentine Express Corp. v. EAN Holdings, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ballentine Express Corp. v. EAN Holdings, LLC, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0322n.06

No. 23-5226

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

BALLENTINE EXPRESS CORP., ) FILED ) Jul 24, 2024 Plaintiff-Appellant, ) KELLY L. STEPHENS, Clerk ) v. ) ) ON APPEAL FROM THE UNITED EAN HOLDINGS, LLC, dba Enterprise ) STATES DISTRICT COURT FOR Rentals, ) THE WESTERN DISTRICT OF Defendant-Appellee, ) TENNESSEE ) STEVEN D. BARKSDALE, ) OPINION ) Defendant. ) )

Before: SUTTON, Chief Judge; STRANCH and DAVIS, Circuit Judges.

JANE B. STRANCH, Circuit Judge. This case involves various challenges to pretrial

and trial decisions during an insurance dispute. Plaintiff Ballentine Express Corporation (BEC)

sought a declaratory judgment against EAN Holdings, LLC (Enterprise), asking the district court

to declare that Enterprise owed BEC $750,000 of Business Travel Insurance. After the court

denied cross-motions for summary judgment, the case proceeded to trial, where the jury rejected

BEC’s contention that the parties had agreed to $750,000 in coverage. BEC appeals the court’s

denial of its partial summary judgment motion and numerous decisions made at and before trial.

We AFFIRM. No. 23-5226, Ballentine Express Corp. v. EAN Holdings, LLC

I. BACKGROUND

BEC was a Memphis-based commercial trucking company owned and operated by Joseph

Ballentine. As a freight carrier, BEC contracted with various companies to haul goods to

customers. Mr. Ballentine owned, leased, and rented box trucks to conduct BEC’s business.

In August 2017, BEC and Enterprise executed a Master Truck Rental Agreement. The

Master Agreement applied to each of BEC’s subsequent truck rentals from Enterprise and was

governed by Tennessee law. Under the Master Agreement, unless BEC maintained liability

protection for accidents through Enterprise itself, it was required to provide a certificate of

insurance showing that it separately maintained certain other insurance. Among the insurance that

BEC was required to maintain in such a scenario was

liability for negligence arising out of the use or operation of vehicles by its employees or agents (including all Drivers) with minimum split limits of $100,000 bodily injury or death per person, $300,000 bodily injury or death per occurrence and $50,000 property damage per occurrence, or a combined single limit of $300,000 . . . .

R. 37-1 ¶ 13(a), Master Agreement, PageID 272.

Enterprise offered optional liability protection for accidents through “Business Travel

Insurance,” or “BTI.” As of early November 2017, BEC was not being charged for BTI under the

Master Agreement. BEC’s account was then updated in mid-November to add BTI coverage,

though the parties would later dispute the amount of coverage provided.

On January 5, 2018, BEC rented a truck from Enterprise weighing over 10,000 pounds. A

day later, while driving the rented truck, one of BEC’s drivers got into an accident with Steven

Barksdale. Barksdale sued BEC in Mississippi in September 2019 for over $2 million in damages.

According to BEC, Enterprise initially declined to offer BEC any coverage for liability in the

Mississippi case, and then later offered only $100,000 in coverage. In April 2021, BEC initiated

-2- No. 23-5226, Ballentine Express Corp. v. EAN Holdings, LLC

this case in the Western District of Tennessee. BEC titled its operative complaint as one for

declaratory judgment and sought several forms of declaratory relief. Among other requests, BEC

asked the court to declare that Enterprise breached duties under the Motor Carrier Act of 1980

(MCA) and the Federal Motor Carrier Safety Regulations (FMCSR), and that Enterprise was liable

for $750,000 or more in damages in the Mississippi lawsuit.

Enterprise filed a motion for partial dismissal. It argued that as an insurer (rather than a

motor carrier), it was not subject to requirements established by the MCA and the FMCSR,

including the FMCSR’s requirement that vehicles over 10,000 pounds carry $750,000 or more in

financial responsibility. See 49 C.F.R. § 387.9(1). The district court agreed, finding that neither

the MCA, FMCSR, nor analogous Tennessee law imposed on Enterprise a duty to provide liability

coverage of $750,000. But it also noted that an insurer could agree to provide coverage conforming

to the MCA or FMSCR. Ultimately, it found the Master Agreement ambiguous regarding the

amount of coverage provided, and declined to resolve the case at the pleadings stage.

The parties filed cross-motions for summary judgment, and while they were pending, the

district court held a pretrial conference on February 3, 2023. At the conference, BEC contended

that it had pleaded not only a declaratory judgment action but also actions for breach of contract

and negligent failure to procure insurance coverage, and that these claims should also be sent to

the jury. Enterprise disagreed, noting that it had prepared its case and witnesses expecting that it

would not have to address any damages issues. Expressing doubt as to whether BEC’s complaint

could be read as encompassing a negligence claim, the court noted that it found the “question about

a breach” of contract claim “a little closer.” After hearing argument, the court expressed concern

that adding any claim could “add[] a layer of complexity” to what it viewed as a “pretty

-3- No. 23-5226, Ballentine Express Corp. v. EAN Holdings, LLC

straightforward” declaratory judgment action, and made no final decision on exactly which claims

the jury would be asked to decide.

On February 7, the district court denied both parties’ summary judgment motions. BEC’s

motion for partial summary judgment had focused on an excess insurance policy between ACE

American Insurance Company and Enterprise (the ACE Policy). The ACE Policy covers, as

“additional insureds,” renters like BEC who purchased insurance coverage through Enterprise and

specifies that it will cover only losses in excess of Enterprise’s “retained limit,” which it defines

as “equal to the minimum financial responsibility required by state.” BEC requested that the court

make several findings concerning Tennessee statutory law and Enterprise’s obligations under the

ACE Policy, including that this Policy obligated Enterprise to tender $750,000 to BEC. Enterprise

argued—among other things—that interpretation of the ACE Policy was not fairly encompassed

within BEC’s amended complaint, which sought adjudication of rights of the “Master Truck Rental

Agreement, the insurance liability protection purchased by Ballentine from Enterprise thereunder,

and state and federal law in relation to the Barksdale Lawsuit.” The district court agreed with

Enterprise, found that BEC’s request to adjudicate the ACE Policy represented a new claim not

properly presented in a summary judgment motion, and denied BEC’s motion.

The court took up additional issues at a second pretrial conference on February 16. First,

it denied BEC’s motion to prevent Enterprise from introducing Ballentine’s prior criminal

convictions for the purpose of impeaching his testimony at trial. The court specified, however,

that while Enterprise would be able to mention the fact that he “was convicted,” it would not be

permitted to “get into the factual background” of the convictions. Next, it noted that it was

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Ballentine Express Corp. v. EAN Holdings, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ballentine-express-corp-v-ean-holdings-llc-ca6-2024.