Erie Insurance Company v. Works

CourtDistrict Court, E.D. Kentucky
DecidedMarch 4, 2025
Docket2:24-cv-00124
StatusUnknown

This text of Erie Insurance Company v. Works (Erie Insurance Company v. Works) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Erie Insurance Company v. Works, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION (at Covington) ERIE INSURANCE COMPANY, etal., □□□ ) Plaintiffs, ) Civil Action No. 2: 24-124-DCR ) V. ) ) TIFFANY WORKS, ) MEMORANDUM OPINION ) AND ORDER Defendant. ) ok 2 2k ok 2 2k ok 2 2k 3 2 2k On June 4, 2023, twenty-month-old Layla Eastman (““Eastman’’) drowned in Defendant Tiffany Works’ (“Works”) outdoor swimming pool while under her foster care. This litigation ensued thereafter.' Two issues are currently pending for consideration. First, should the Court exercise jurisdiction under the Declaratory Judgment Act. Second, if the Court exercises jurisdiction under the act, is Works covered by either of two insurance policies issued by Plaintiff Erie Insurance Company (“Erie’’).? These questions are presented in a motion to dismiss filed by Works [Record No. 25], and Erie’s motion for summary judgment. [Record No. 15] After fully considering the matter, the undersigned concludes that exercise of jurisdiction is proper and a factual issue is presented regarding one of the subject policies which cannot be resolved through summary judgment. As a result, Works’ motion to dismiss

The present action is derivative of a matter pending in the Kenton Circuit Court. See Estate of Layla Eastman, et al., v. Cabinet for Health and Family Services, et al., Civil Action No. 24-CI-110 (hereafter, the “underlying action”). 2 Works holds a homeowner’s policy and an umbrella policy with Erie. -|-

will be denied, and Erie’s motion for summary judgment will be granted, in part, and denied, in part. I.

On June 1, 2022, ten-month-old Layla Eastman and her two-year-old brother were temporarily placed in the custody of the Kentucky Cabinet for Health and Family Services (“CHFS”) while their parents were “provided with services”.3 [Record No. 25-1, ¶ 16] “The goal was to return [Eastman] and her brother to … their parents, as soon as possible.” [Id.] Initially, the children were placed with a two parent foster family with no other children in the home. [Id., ¶ 16] However, when the couple discovered they were expecting a child of their own, they were no longer able to provide Eastman and her brother the attention they needed.

Thereafter, on February 3, 2023, Eastman and her brother were transferred to the home of Defendant Tiffany Works. [Id., ¶ 21; Record No. 15-3] Prior to this placement, Eastman and her brother visited their biological parents in their home each week. [Id., ¶ 20] Works provided foster care for two other children in addition to Eastman and her brother. [Id., ¶ 23] In February of 2023, Eastman’s parents expressed concerns their children were permitted to “‘run wild at the foster home[.]’” [Id., ¶ 25] About a month later, Eastman’s parents “were transitioning to the return of their children to their custody with each having

unsupervised parenting time and obtaining furnishings for the children to return home.” [Id.,

3 In addressing the motion to dismiss under Rule 12(6) of the Federal Rules of Civil Procedure, the Court takes the facts as alleged in the Complaint, drawing all reasonable inferences in the nonmoving party’s favor. Directv, Inc. v. Treesh, 487 F.3d 471, 476 (6th Cir. 2007). In analyzing the motion for summary judgment, the facts are viewed in the light most favorable to the non-moving party. The undersigned does not look beyond the pleadings to resolve the 12(b)(6) motion. However, the Court looks beyond the pleadings when addressing the motion for summary judgment. See Celotex Corp. v. Catrett, 477 U.S. 317, 322–23 (1986). ¶ 28] On May 23, 2023, CHFS employees noted that Works’ “‘home always smells like urine, due to multiple dogs’” and that Eastman “was not doing well in day care[.]” [Id., ¶ 31] Works’ home had an uncovered outdoor above ground pool, accessible by walking

outside onto a wooden deck, which led directly to the pool’s edge. [Id., ¶ 22] On June 4, an unsupervised Eastman left a bedroom in Works’ home and wandered outside into the swimming pool. [Id., ¶¶ 33-34] At least an hour later, Works discovered that the child had drowned. [Id.] Later that day, Eastman’s brother was removed from the home and returned to his parents. [Id., ¶ 36]4 Around June 3, 2024, Eastman’s parents filed the underlying action against Works and others alleging negligence, gross negligence, and negligence per se. [Record No. 15-1, p. 2]

At the time of Eastman’s death, “Works was the named insured on an ErieSecure Home Insurance Policy … for the period of March 13, 2023 through March 13, 2024 … [and] Works was also the named insured under a Personal Umbrella Policy … for the same policy period.” [Id., pp. 2-3] II. A complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). To survive a motion to dismiss under

Federal Rule of Civil Procedure 12(b)(6), the complaint must contain “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). While the court makes all reasonable inferences in favor of the non-moving party, the plaintiff must plead factual content that allows the court to draw the

4 The Kenton County Family Court formally returned Eastman’s brother to his parents’ custody on July 11, 2024. [Id., ¶ 37] reasonable inference that the defendant is liable for the conduct alleged. Id. (citing Bell Atlantic Co. v. Twombly, 550 U.S. 544, 556 (2007)). III.

The Declaratory Judgment Act provides, in relevant part, that: [A]ny court of the United States, upon the filing of an appropriate pleading, may declare the rights and other legal relations of any interested party seeking such declaration, whether or not further relief is or could be sought. Any such declaration shall have the force and effect of a final judgment or decree and shall be reviewable as such.

28 U.S.C. § 2201(a). To evaluate whether jurisdiction is exercised appropriately under the Declaratory Judgment Act, the Court weighs the following factors outlined in Grand Trunk W. R.R. Co. v. Consol. Rail Corp.: (1) whether the declaratory action would settle the controversy; (2) whether the declaratory action would serve a useful purpose in clarifying the legal relations in issue; (3) whether the declaratory remedy is being used merely for the purpose of “procedural fencing” or “to provide an arena for a race for res judicata;” (4) whether the use of a declaratory action would increase friction between our federal and state courts and improperly encroach upon state jurisdiction; and (5) whether there is an alternative remedy which is better or more effective.

United Specialty Ins. Co. v. Cole’s Place, Inc., 936 F.3d 386, 396 (6th Cir. 2019) (quoting Grand Trunk W. R.R. Co. v. Consol. Rail Corp., 746 F.2d 323, 326 (6th Cir. 1984)).

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Erie Insurance Company v. Works, Counsel Stack Legal Research, https://law.counselstack.com/opinion/erie-insurance-company-v-works-kyed-2025.