Esurance Ins. Co. v. Hamm

387 F. Supp. 3d 1134
CourtDistrict Court, D. Oregon
DecidedApril 30, 2019
DocketCiv. No. 1:18-cv-01715-MC
StatusPublished
Cited by1 cases

This text of 387 F. Supp. 3d 1134 (Esurance Ins. Co. v. Hamm) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Esurance Ins. Co. v. Hamm, 387 F. Supp. 3d 1134 (D. Or. 2019).

Opinion

"State law determines the court's interpretation of insurance policy and an insurer's duty to defend and indemnify." Allstate Ins. Co. v. Morgan , 123 F. Supp.3d 1266, 1272-73 (D. Or. 2015) (citing Larson Const. Co. v. Or. Auto. Ins. Co. , 450 F.2d 1193, 1195 (9th Cir. 1971) ). Under Oregon law, the duty to defend is "distinct from, and is broader than, the duty to indemnify under the terms of an insurance policy." Id. at 1273 (citing Ledford v. Gutoski , 319 Or. 397, 403, 877 P.2d 80 (1994) ). Although the duty to defend and the duty to indemnify turn on the terms of the policy, they are independent of one another.

*1138W. Hills Dev. Co. v. Chartis Claims, Inc. , 360 Or. 650, 652, 385 P.3d 1053 (2016). An insurer might be obliged to defend a case that results in a verdict that is not covered by the insured's policy, or an insurer might not be obliged to defend the insured but the case results in a judgment that is covered by the policy, which requires indemnification. Id. at 652-53, 385 P.3d 1053.

An insurer's duty to defend is determined by comparing the complaint to the insurance policy, under what is known as the "four-corners" rule. W. Hills Dev. Co. , 360 Or. at 653, 385 P.3d 1053. "If the allegations in the complaint assert a claim that is covered by the policy, then the insurer has a duty to defend." Id. Conversely, if the allegations of the complaint do not assert a claim covered by the policy, then there is no duty to defend. Id. This analysis generally precludes any consideration of extrinsic evidence. Id. "Although an insurer's duty to defend depends on the pleading, the insurer has a duty to defend the insured only 'if the claim made against the insured is one covered by the insurer.' " Morgan , 123 F. Supp.3d at 1273 (quoting Casey v. Nw. Sec. Ins. , 260 Or. 485, 489, 491 P.2d 208 (1971) ). "While a duty to defend is triggered by the allegations in a pleading, the duty to indemnify is proven by facts that establish a right to coverage." Id.

The insured bears the burden of proving coverage, while the insurer has the burden of proving exclusion from coverage. ZRZ Realty Co. v. Beneficial Fire & Cas. Ins. Co. , 349 Or. 117, 127, 241 P.3d 710 (2010). "Thus, if the insurer can establish that the insured is precluded from coverage, it has neither the duty to defend, nor the duty to indemnify the insured." Morgan , 123 F. Supp.3d at 1273.

Esurance alleges that, under the terms of the Hamms' policy, it is not obliged to either defend or indemnify because the injury alleged by Pina in the underlying case was the result of a criminal act by Seth Hamm. As relevant to this issue, the Hamms' policy provides:

"We" [Esurance] do not cover any "bodily injury" or "property damage" intended by, or which may reasonably be expected to result from the intentional or criminal acts or omissions of, any "insured person". This exclusion applies even if:
a) such "insured person" lacks the mental capacity to govern his or her conduct;
b) such "bodily injury" or "property damage" is of a difference kind or degree than intended or reasonably expected; or
c) such "bodily injury" or "property damage" is sustained by a different person than intended or reasonably expected.
This exclusion applies regardless of whether such "insured person" is actually charged with, or convicted of, a crime.

Lanz Decl. Ex. C, at 30. ECF No. 16-1.

A. Duty to Defend and Indemnify Seth Hamm

In the present case, Pina has dismissed the underlying lawsuit against Seth Hamm. Esurance seeks a declaration that it has no duty to defend if and when Pina refiles his claim. The Oregon Supreme Court has held that the duty to defend must be assessed by comparing the policy to the complaint and that such an assessment must generally be made without reference to extrinsic evidence. W. Hills Dev. Co. , 360 Or. at 653-54,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
387 F. Supp. 3d 1134, Counsel Stack Legal Research, https://law.counselstack.com/opinion/esurance-ins-co-v-hamm-ord-2019.