Berkshire Hathaway Homestate Insurance Company v. Messer-Bowers Company

CourtDistrict Court, D. Nebraska
DecidedFebruary 28, 2025
Docket8:24-cv-00295
StatusUnknown

This text of Berkshire Hathaway Homestate Insurance Company v. Messer-Bowers Company (Berkshire Hathaway Homestate Insurance Company v. Messer-Bowers Company) is published on Counsel Stack Legal Research, covering District Court, D. Nebraska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Berkshire Hathaway Homestate Insurance Company v. Messer-Bowers Company, (D. Neb. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

BERKSHIRE HATHAWAY HOMESTATE INSURANCE COMPANY; 8:24CV295 Plaintiff,

vs. MEMORANDUM AND ORDER

MESSER-BOWERS COMPANY;

Defendant.

Before the Court is Defendant’s Motions to Compel Arbitration and Dismiss Plaintiff’s Complaint. Filing No. 7.1 For the reasons set forth herein, the Court grants Defendant’s motion and stays further proceedings. BACKGROUND On July 24, 2024, Plaintiff filed a complaint alleging breach of contract, unjust enrichment, and equitable indemnity. Filing No. 1. The complaint alleges the action arises “from an error [Defendant] committed in its capacity as an insurance agent” and cites various portions of an April 26, 2016 agency agreement between Plaintiff and Defendant (‘the Agreement”). Filing No. 1. Plaintiff claims Defendant breached its contract when Defendant, in its capacity as an insurance agency, inaccurately represented in an application that a third party had a certain fire protective safeguard inducing Plaintiff to issue a commercial property insurance policy. Thereafter, Plaintiff alleges Defendant did not indemnify Plaintiff pursuant to the parties’ indemnity agreement or give Defendant’s errors and omissions

1 There is a split of authority on the issue, but judges within the District of Nebraska have held that motions to arbitrate are non-dispositive and can be ruled on by a magistrate judge. See All. Grp., Inc. v. Zurich Am. Ins. Co., No. 8:21CV188, 2021 WL 5325883, at *1 (D. Neb. Nov. 16, 2021) (“This Court agrees with those courts holding that ‘a motion to compel arbitration is a non-dispositive motion’ and can be decided by a magistrate judge.”). carrier notice of its mistake. Plaintiff bases its equitable indemnity claim on these facts. Plaintiff also alleges Defendant was unjustly enriched when it received commissions from Plaintiff, which included for the policy at issue. On November 11, 2024, Defendant filed its motion to compel arbitration, attaching the Agreement as evidence. Filing Nos. 7, 9-1. Relevant portions of the Agreement, for purposes of the pending motion, are set forth below: VII. ARBITRATION Company and Agency agree that disputes between them arising out of this Agreement and related to the amount of commission or other monies owed to Agency by Company shall be settled by binding arbitration pursuant to the procedures and rules set forth by the American Arbitration Association (“AAA”). . . . . . . XV. GENERAL PROVISIONS . . . B. Venue The parties hereto agree that the United States District Court for the District of Nebraska and the District Court of Douglas County, Nebraska, shall be the sole and exclusive forums in which to file suit for disputes arising out of or related to this Agreement. The parties irrevocably consent to jurisdiction and to venue. Filing No. 9-1 at 10-11.

ANALYSIS I. Standard of Review In deciding a motion to compel arbitration where the parties rely on matters outside the pleadings, the Court applies a standard akin to summary judgment. Tinder v. Pinkerton Security, 305 F.3d 728, 735 (7th Cir. 2002) (“The FAA does not expressly identify the evidentiary standard a party seeking to avoid compelled arbitration must meet. But courts that have addressed the question have analogized the standard to that required of a party opposing summary judgment under Rule 56(e) of the Federal Rules of Civil Procedure.”); see also Seldin v. Seldin, 879 F.3d 269, 272 (8th Cir. 2018). Therefore, the Court will “view[] the evidence in the light most favorable to the nonmoving party” and grant the motion if “‘there is no genuine dispute as to any material fact and . . . the movant is entitled to judgment as a matter of law.’” DeLuna v. Mower Cty., 936 F.3d 711, 716 (8th Cir. 2019) (quoting Brunsting v. Lutsen Mountains Corp., 601 F.3d 813, 820 (8th Cir. 2010). II. Validity and Scope of Arbitration Agreement As noted above, the Agreement contains an arbitration provision that states “disputes between them arising out of this Agreement and related to the amount of commission or other monies owed to Agency by Company shall be settled by binding arbitration . . .” Filing No. 9-1 at 10. Based on this language, Defendant seeks an order compelling arbitration of the parties’ dispute pursuant to the Federal Arbitration Act (“FAA”). See 9 U.S.C. §§ 1 et seq. The FAA provides “[a] written provision in any ... contract evidencing a transaction involving commerce to settle by arbitration a controversy thereafter arising out of such contract or transaction ... shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.” 9 U.S.C. § 2. This provision reflects “a liberal federal policy favoring arbitration agreements, notwithstanding any state substantive or procedural policies to the contrary.” Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 24 (1983). The plain language of the Agreement indicates the Agreement involves a transaction involving commerce. In reviewing a motion to compel arbitration, the Court must determine “(1) whether there is a valid arbitration agreement and (2) whether the particular dispute falls within the terms of that agreement.” Robinson v. EOR-ARK, LLC, 841 F.3d 781, 783-84 (8th Cir. 2016) (quoting Faber v. Menard, Inc., 367 F.3d 1048, 1052 (8th Cir. 2004)). The Court must grant a motion to compel arbitration “if a valid arbitration clause exists which encompasses the dispute between the parties.” 3M Co. v. Amtex Sec., Inc., 542 F.3d 1193, 1198 (8th Cir. 2008). Whether a valid arbitration agreement exists is a question of state contract law. Donaldson Co., Inc. v. Burroughs Diesel, Inc., 581 F.3d 726, 731 (8th Cir. 2009). The parties do not dispute validity of the Agreement. Instead, the Plaintiff contends the present claims fall outside the terms of the arbitration provision. Filing No. 12. Because it is undisputed that a valid agreement exists, “‘[t]he party resisting arbitration bears the burden of showing either that the arbitration provision is invalid or that it does not encompass the claims at issue.’” H&T Fair Hills, Ltd. v. Alliance Pipeline L.P., 76 F.4th 1093 (8th Cir. 2023) (quoting Triplet v. Menard, Inc., 42 F.4th 868, 870 (8thCir. 2022). A court must “liberally construe” a valid arbitration agreement. Parm v. Bluestem Brands, Inc., 898 F.3d 869, 873 (8th Cir. 2018) (citing AT&T Techs., Inc. v. Commc’ns Workers of Am., 475 U.S. 643, 650 (1986) (“[A]n order to arbitrate the particular grievance should not be denied unless it may be said with positive assurance that the arbitration clause is not susceptible of an interpretation that covers the asserted dispute.

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Related

Brunsting v. Lutsen Mountains Corp.
601 F.3d 813 (Eighth Circuit, 2010)
At&T Technologies, Inc. v. Communications Workers
475 U.S. 643 (Supreme Court, 1986)
Ilah M. Tinder v. Pinkerton Security
305 F.3d 728 (Seventh Circuit, 2002)
Steve R. Faber v. Menard, Inc.
367 F.3d 1048 (Eighth Circuit, 2004)
Donaldson Co., Inc. v. Burroughs Diesel, Inc.
581 F.3d 726 (Eighth Circuit, 2009)
3M Co. v. Amtex Security, Inc.
542 F.3d 1193 (Eighth Circuit, 2008)
Unison Co., Ltd. v. Juhl Energy Development, Inc.
789 F.3d 816 (Eighth Circuit, 2015)
Eddie Robinson v. EOR-ARK, LLC
841 F.3d 781 (Eighth Circuit, 2016)
Scott Seldin v. Theodore Seldin
879 F.3d 269 (Eighth Circuit, 2018)
Jessica Parm v. Bluestem Brands, Inc.
898 F.3d 869 (Eighth Circuit, 2018)

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Berkshire Hathaway Homestate Insurance Company v. Messer-Bowers Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/berkshire-hathaway-homestate-insurance-company-v-messer-bowers-company-ned-2025.