Delaine Petersen v. Kirk Huehn

CourtCourt of Appeals of Iowa
DecidedSeptember 2, 2020
Docket19-1594
StatusPublished

This text of Delaine Petersen v. Kirk Huehn (Delaine Petersen v. Kirk Huehn) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Delaine Petersen v. Kirk Huehn, (iowactapp 2020).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 19-1594 Filed September 2, 2020

DELAINE PETERSEN, Plaintiff-Appellant,

vs.

KIRK HUEHN, Defendant-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Carroll County, Gary McMinimee,

Judge.

Delaine Petersen appeals an order granting Kirk Huehn’s motion for

summary judgment. AFFIRMED.

Steven Hamilton of Hamilton Law Firm, P.C., Storm Lake, for appellant.

Ryan Stefani of Nyemaster Goode, P.C., Des Moines, for appellee.

Considered by Tabor, P.J., and May and Greer, JJ. 2

MAY, Judge.

Delaine Petersen appeals an order granting Kirk Huehn’s motion for

summary judgment on grounds of claim preclusion. We affirm.

I. Background Facts and Prior Proceedings

Petersen owned a custom-built motorcycle. He sought insurance for the

motorcycle from Huehn, an agent of State Farm Automobile Insurance Company

(State Farm). Petersen asked for coverage in the amount of $35,000—the value

he ascribed to the motorcycle. State Farm issued Petersen a policy covering the

motorcycle for the period of April 24, 2014, through April 24, 2015. On or about

April 13, 2015, Petersen claims the motorcycle sustained a total loss. Petersen

submitted a claim to State Farm requesting $35,000. Petersen alleges State Farm

denied coverage.

In March 2018—almost three years after the alleged total loss of the

motorcycle—Petersen filed suit against State Farm. In that case, Petersen alleged

State Farm denied his claim in bad faith. State Farm removed the case to the

United States District Court for the Southern District of Iowa (Southern District).

State Farm then filed a motion to dismiss. State Farm argued Petersen’s suit was

barred by the policy’s one-year limitation period. The Southern District agreed and

dismissed Petersen’s suit. The Eighth Circuit Court of Appeals affirmed. See

Petersen v. State Farm Mut. Auto. Ins. Co., 750 F. App’x 517, 518 (8th Cir. 2019).

In July 2018, Petersen filed the present suit against Huehn. Petersen

alleges Huehn was negligent in representing to Petersen that he received a stated

value policy for $35,000. Because of this negligence, Petersen claims he “has 3

been deprived of the insurance amount he was told that he had by Defendant

Huehn.”

Huehn moved for summary judgment. The district court granted the motion

on the basis of claim preclusion. Petersen now appeals.

II. Standard of Review

“[W]e review a district court’s grant of summary judgment for correction of

errors at law.” Boelman v. Grinnell Mut. Reinsurance Co., 826 N.W.2d 494, 500

(Iowa 2013). Summary judgment is proper “when the moving party demonstrates

there is no genuine issue of material fact and that [the party] is entitled to judgment

as a matter of law.” Id. at 501. We may resolve a matter on summary judgment if

the only conflict concerns legal consequences of undisputed facts. Id.

III. Analysis

In general, “claim preclusion holds that a valid and final judgment on a claim

bars a second action on the adjudicated claim or any part thereof.” Pavone v.

Kirke, 807 N.W.2d 828, 835 (Iowa 2011). In effect, “a party must litigate all matters

growing out of the claim.” Penn v. Iowa State Bd. of Regents, 577 N.W.2d 393,

398 (Iowa 1998). And claim preclusion “applies not only to matters actually

determined in an earlier action but to all relevant matters that could have been

determined.” Shumaker v. Iowa Dep’t of Transp., 541 N.W.2d 850, 852 (Iowa

1995). So, claim preclusion may bar litigation on matters the parties never litigated

in the first claim. Arnevik v. Univ. of Minn. Bd. of Regents, 642 N.W.2d 315, 319

(Iowa 2002).

To establish claim preclusion a party must show: (1) the parties in the first and second action are the same parties or parties in privity, (2) there was a final judgment on the merits in the first action, and (3) 4

the claim in the second suit could have been fully and fairly adjudicated in the prior case (i.e., both suits involve the same cause of action).

Pavone, 807 N.W.2d at 836. If any element is missing, a defense of claim

preclusion will fail. Arnevik, 642 N.W.2d at 319.

We start with the first element, whether the parties were the same or in

privity. Petersen was the plaintiff in both cases. And, throughout both cases,

Petersen has maintained that State Farm and Huehn are principal and agent.

Consistent with this approach, Petersen does not deny that State Farm and Huehn

are in privity. So we consider the first element satisfied.

We turn next to the second element, whether there was a final judgment in

the prior case. This is not disputed, either. The parties agree that the previous

action—Petersen v. State Farm—ended in a final judgment on the merits.

Specifically, the Southern District granted State Farm’s motion to dismiss, and the

Eighth Circuit affirmed. See Petersen, 750 F. App’x at 518. The second element

is satisfied.

We turn then to the third and final element. To determine whether a claim

could have been fully and fairly adjudicated in the prior case—whether both suits

involve the same cause of action—we look at whether there is

a natural grouping or common nucleus of operative facts. Among the factors relevant to a determination [of] whether the facts are so woven together as to constitute a single claim are their relatedness in time, space, origin, or motivation, and whether, taken together, they form a convenient unit for trial purposes. . . . If there is a substantial overlap, the second action should ordinarily be held precluded.

Pavone, 807 N.W.2d at 837 (quoting Restatement (Second) of Judgments § 24

cmt. b (Am. Law Inst. 1982)). Even if “different harms, substantive theories, 5

measures[,] or kinds of relief” are brought, there may still be a single cause of

action. Villarreal v. United Fire & Cas. Co., 873 N.W.2d 714, 721 (Iowa 2016)

(quoting Restatement (Second) of Judgments § 24 cmt. c). And parties are “not

entitled to a ‘second bite’ simply by alleging a new theory of recovery for the same

wrong.” Bennett v. MC No. 619, Inc., 586 N.W.2d 512, 517 (Iowa 1998).

Like the district court, we believe the overlap between the two cases is more

than sufficient. Both cases depended on the same allegations of fact, namely,

(1) Petersen owned a motorcycle; (2) Petersen valued his motorcycle at $35,000;

(3) Petersen wanted insurance that would pay $35,000; (4) Huehn told Petersen

he procured a State Farm policy that would pay $35,000; (5) Petersen’s motorcycle

suffered a total loss; (6) Petersen made a claim with State Farm for $35,000; and

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Related

Shumaker v. Iowa Department of Transportation
541 N.W.2d 850 (Supreme Court of Iowa, 1995)
Arnevik v. University of Minnesota Board of Regents
642 N.W.2d 315 (Supreme Court of Iowa, 2002)
Top of Iowa Cooperative v. Sime Farms, Inc.
608 N.W.2d 454 (Supreme Court of Iowa, 2000)
Meier v. SENECAUT III
641 N.W.2d 532 (Supreme Court of Iowa, 2002)
Penn v. Iowa State Board of Regents
577 N.W.2d 393 (Supreme Court of Iowa, 1998)
Bennett v. MC 619, INC.
586 N.W.2d 512 (Supreme Court of Iowa, 1998)

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