Ex parte Kentucky Farm Bureau Mutual Insurance Company PETITION FOR WRIT OF MANDAMUS (In re: Rebecca Henderson v. Kentucky Farm Bureau Mutual Insurance Company) (Baldwin Circuit Court: CV-24-901036).

CourtSupreme Court of Alabama
DecidedMarch 21, 2025
DocketSC-2024-0608
StatusPublished

This text of Ex parte Kentucky Farm Bureau Mutual Insurance Company PETITION FOR WRIT OF MANDAMUS (In re: Rebecca Henderson v. Kentucky Farm Bureau Mutual Insurance Company) (Baldwin Circuit Court: CV-24-901036). (Ex parte Kentucky Farm Bureau Mutual Insurance Company PETITION FOR WRIT OF MANDAMUS (In re: Rebecca Henderson v. Kentucky Farm Bureau Mutual Insurance Company) (Baldwin Circuit Court: CV-24-901036).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte Kentucky Farm Bureau Mutual Insurance Company PETITION FOR WRIT OF MANDAMUS (In re: Rebecca Henderson v. Kentucky Farm Bureau Mutual Insurance Company) (Baldwin Circuit Court: CV-24-901036)., (Ala. 2025).

Opinion

Rel: March 21, 2025

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2024-2025

_________________________

SC-2024-0608 _________________________

Ex parte Kentucky Farm Bureau Mutual Insurance Company

PETITION FOR WRIT OF MANDAMUS

(In re: Rebecca Henderson

v.

Kentucky Farm Bureau Mutual Insurance Company)

(Baldwin Circuit Court: CV-24-901036)

McCOOL, Justice. SC-2024-0608

Kentucky Farm Bureau Mutual Insurance Company ("Kentucky

Farm Bureau") has petitioned this Court for a writ of mandamus

directing the Baldwin Circuit Court to dismiss the claim filed against it

by its insured, Rebecca Henderson.

Facts and Procedural History

In August 2022, Henderson and her minor son were involved in an

automobile collision in Alabama when the car that Henderson was

driving was struck by the car that Trey Allan Knapp was driving. At that

time, Henderson had an insurance policy that she had purchased from

Kentucky Farm Bureau, and that policy provided her with uninsured-

motorist ("UM") benefits. In July 2024, Henderson filed a complaint in

the circuit court, in which she asserted a negligence/wantonness claim

against Knapp and a claim for "damages by contract" against Kentucky

Farm Bureau. In support of her contract claim, Henderson alleged that

she and her son are both residents of Kentucky, that Kentucky Farm

Bureau "is an insurance company doing business in the State of

Kentucky," that Knapp is a resident of Alabama, and that Knapp "did not

2 SC-2024-0608

have any liability insurance available." Thus, according to Henderson,

she was entitled to UM benefits from Kentucky Farm Bureau. 1

Kentucky Farm Bureau filed a motion to dismiss Henderson's claim

for UM benefits, arguing that the circuit court lacked personal

jurisdiction over Kentucky Farm Bureau. See Rule 12(b)(2), Ala. R. Civ.

P. In support of its motion, Kentucky Farm Bureau contended that it is

"authorized to do business and issu[es] insurance policies only in the

State of Kentucky," that it had issued Henderson's insurance policy "at

her address [in] Kentucky," that it "does not issue any insurance policies

in the State of Alabama or conduct business in the State of Alabama,"

and that it "has not availed itself of the jurisdiction of any court in

Alabama." Kentucky Farm Bureau supported those contentions with an

affidavit from Anthony Strode, a "Litigation Supervisor for Kentucky

Farm Bureau," who attested that Kentucky Farm Bureau

"does not do business in the State of Alabama, does not issue insurance policies in the State of Alabama, and has no continuous and systematic contacts for business purposes in Alabama. The automobile policy of insurance was issued to Rebecca Henderson by [Kentucky Farm Bureau] in Kentucky and delivered to her address [in] Kentucky."

1We note that Henderson did not allege in her complaint that she

had filed a claim for UM benefits with Kentucky Farm Bureau or that Kentucky Farm Bureau had denied such a claim. 3 SC-2024-0608

Thus, according to Kentucky Farm Bureau, because it has no "continuous

and systematic" contacts with Alabama, Henderson's "claim for UM

benefits is a contract action which should have been filed in the State of

Kentucky."

In her response to Kentucky Farm Bureau's motion, Henderson

argued that Kentucky Farm Bureau does have contacts with Alabama

that are sufficient to allow the circuit court to exercise personal

jurisdiction over it. In support of that argument, Henderson contended

that her insurance policy "covers her and her family in the event of a

motor-vehicle wreck regardless of where they are physically located at

the time of said wreck." Thus, according to Henderson, by issuing an

insurance policy that provides nationwide coverage, Kentucky Farm

Bureau had "purposefully availed itself of the privilege of conducting

activities within Alabama" and therefore "should anticipate being haled

to court in any state -- not just Alabama." Henderson's response also

included her affidavit, in which she attested:

"I purchased a policy of insurance with Kentucky Farm Bureau to cover me and my family in the event of a motor vehicle wreck. It is my understanding that this policy of insurance covers me and my family not only in Kentucky, but also in every other state, including Alabama. In fact, it was 4 SC-2024-0608

my intent to purchase a policy that provided me coverage in all 50 states and it is my understanding that it was Kentucky Farm Bureau's intent to sell me a policy that extended coverage to all 50 states. No one at Kentucky Farm Bureau has ever told me otherwise.

"….

"In other words, my Kentucky Farm Bureau insurance policy extends coverage to me in all 50 states. I was involved in a wreck in Alabama, the at-fault party was a resident of Alabama and was cited by an Alabama police officer, and my policy with Kentucky Farm Bureau providing me coverage while in Alabama was in effect on the date of that wreck."

In response to Henderson's argument, Kentucky Farm Bureau

argued that "[t]here is a difference between a contract action such as

[Henderson's] claim for [UM] benefits and a tort action against an

insured." According to Kentucky Farm Bureau, "had Henderson been

sued as a result of an automobile accident in [Alabama], then [it] would

provide a defense for her since she had allegedly committed a tortious act

in [Alabama] which would allow for personal jurisdiction to be asserted."

Kentucky Farm Bureau noted, though, that Henderson had not been

sued as the alleged tortfeasor in this case but, instead, had sued

Kentucky Farm Bureau for UM benefits. Thus, Kentucky Farm Bureau

continued to argue that Henderson's "claim for UM benefits must be

litigated in … Kentucky where [her insurance] policy was issued." 5 SC-2024-0608

On August 27, 2024, the circuit court denied Kentucky Farm

Bureau's motion to dismiss, without stating its reasons, and Kentucky

Farm Bureau timely petitioned this Court for a writ of mandamus.

Standard of Review

" 'A writ of mandamus is an extraordinary remedy, and is appropriate when the petitioner can show (1) a clear legal right to the order sought; (2) an imperative duty upon the respondent to perform, accompanied by a refusal to do so; (3) the lack of another adequate remedy; and (4) the properly invoked jurisdiction of the court. Ex parte Inverness Constr. Co., 775 So. 2d 153, 156 (Ala. 2000).' "

Ex parte Gulf Health Hosps., Inc., 321 So. 3d 629, 632 (Ala. 2020)

(quoting Ex parte BOC Grp., Inc., 823 So. 2d 1270, 1272 (Ala. 2001)).

" '[A] petition for a writ of mandamus is the proper device by which to challenge the denial of a motion to dismiss for lack of in personam jurisdiction. See Ex parte McInnis, 820 So. 2d 795 (Ala.

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Ex parte Kentucky Farm Bureau Mutual Insurance Company PETITION FOR WRIT OF MANDAMUS (In re: Rebecca Henderson v. Kentucky Farm Bureau Mutual Insurance Company) (Baldwin Circuit Court: CV-24-901036)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-kentucky-farm-bureau-mutual-insurance-company-petition-for-writ-of-ala-2025.