Express Jewelry Enterprises, Inc v. National Fire Insurance Company of Hartford

CourtDistrict Court, E.D. Michigan
DecidedAugust 7, 2025
Docket2:23-cv-10615
StatusUnknown

This text of Express Jewelry Enterprises, Inc v. National Fire Insurance Company of Hartford (Express Jewelry Enterprises, Inc v. National Fire Insurance Company of Hartford) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Express Jewelry Enterprises, Inc v. National Fire Insurance Company of Hartford, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

EXPRESS JEWELRY ENTERPRISES, INC., d/b/a HAK’S JEWELRY, Plaintiff, Case No. 23-10615 v. Hon. Denise Page Hood

NATIONAL FIRE INSURANCE COMPANY OF HARTFORD, an Illinois Domiciled property and casualty insurance company,

Defendant. _______________________________/ ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT [ECF NO. 15] I. INTRODUCTION Before the Court is Defendant National Fire Insurance Company of Hartford’s (“NFICH”) Motion for Summary Judgment. [ECF No. 15]. The motion is fully briefed. See [ECF Nos. 16 & 18]. For the reasons stated herein, Defendant’s motion is GRANTED. II. BACKGROUND This is an insurance coverage dispute. Plaintiff Express Jewelry Enterprises, Inc., d/b/a Hak’s Jewelry (“Hak’s Jewelry”) entered an agreement with NFICH for businessowners insurance (Policy No. B6025346371; “the Policy”). [ECF No. 1-2, PageID.13]. The Policy period was active between September 9, 2020, through September 9, 2021. Id. The parties do not dispute that on or about June 25, 2021, during the policy period, Plaintiff experienced severe damage to its business

premises, business personal property and an interruption of its business operations caused by a wind and rain weather event.1 Id. The damage and interruption of business operations was caused by “large amounts of rainwater from this weather

event that could not exit this premises due to a blockage in its drain from the premises to the city sewers.” Id. at PageID.14. Plaintiff filed a claim with NFICH to recover for the loss it sustained during the weather event. Id. NFICH investigated Plaintiff’s claim and concluded that the

cause of any loss was a backup of the drains in the basement of the building. [ECF No. 15, PageID.439]. NFICH denied Plaintiff’s claim because coverage for the damage sustained by Plaintiff is excluded under the Policy.

Plaintiff requests that this Court declare the rights, obligations and duties of himself and Defendant under the policy. Id. at PageID.15. Plaintiff further requests that this Court find that NFICH breached the parties’ agreement by wrongfully denying Plaintiff coverage under the policy.

NFICH moves this Court to for summary judgment because damage arising from sewer/drain backup due to flooding/rain is specifically excluded under the

1 The Court takes judicial notice of the alleged rainstorm as the event is well documented. See Plymouth United Church of Christ (Congregational) v. Philadelphia Indem. Ins. Co., 740 F. Supp. 3d 594 (E.D. Mich. 2024) policy and Plaintiff materially misrepresented the cause of loss, making the insurance policy void. [ECF No. 15, PageID.432-33].

III. LAW AND ANALYSIS Federal Rule of Civil Procedure 56 allows a party to move for summary judgment on some or all counts. Summary judgment is appropriate where “the

movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). The movant must cite to “particular parts of materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations (including

those made for purposes of the motion only), admissions, interrogatory answers, or other materials” to establish that there is no genuine issue for trial. Fed. R. Civ. P. 56(c)(1)(A). “As the party moving for summary judgment, Defendants bear the

burden of showing the absence of a genuine issue of material fact as to at least one essential element of Plaintiff's claim.” Logan v. Denny's, Inc., 259 F.3d 558, 566 (6th Cir. 2001). Courts “must accept Plaintiff's evidence as true and draw all reasonable inferences in her favor[.]” Id. The Court “may not make credibility determinations

nor weigh the evidence before it when determining whether an issue of fact remains for trial.” Id. Once the movant satisfies its initial burden of demonstrating the absence of

any genuine issue of material fact, the burden shifts to the nonmoving party to set forth specific facts showing a triable issue of material fact. Plymouth United Church of Christ (Congregational) v. Philadelphia Indem. Ins. Co., 740 F. Supp. 3d 594, 598

(E.D. Mich. 2024). The “mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment.” Scott v. Harris, 550 U.S. 372, 380, 127 S.Ct. 1769, 167 L.Ed.2d 686

(2007). Michigan law governs the interpretation and application of the policy. Hantz Fin. Servs., Inc. v. Am. Int'l Specialty Lines Ins. Co., 664 F. App'x 452, 456 (6th Cir. 2016). Under Michigan law, “[a]n insurance policy is similar to any other contractual

agreement, and thus, the court’s role is to determine what the agreement was and effectuate the intent of the parties.” Hunt v. Drielick, 496 Mich. 366, 372, 852 N.W.2d 562, 565 (2014) (internal quotation marks omitted). If a contract is clear and

unambiguous, the court must enforce the contract as written, according to its plain meaning, Clevenger v. Allstate Ins. Co., 443 Mich. 646, 654; 505 N.W.2d 553, 557 (1993), without looking to extrinsic evidence. Michigan courts employ a two-part analysis to determine the parties’ intent: (1) determine whether the policy provides

coverage to the insured, and (2) ascertain whether that coverage is negated by an exclusion. Hunt, 496 Mich. at 372, quoting Heniser v. Frankenmuth Mut. Ins. Co., 449 Mich. 155, 172, 534 N.W.2d 502 (1995). “Exclusionary clauses in insurance

policies are strictly construed in favor of the insured.” Auto–Owners Ins. Co. v. Churchman, 440 Mich. 560, 597, 489 N.W.2d 431 (1992). However, it is impossible to hold an insurance company liable for a risk it did not assume, and thus clear and

specific exclusions must be enforced. Hantz, 496 Mich at 373. The parties do not dispute the existence of the policy or whether the claimed damage occurred during the relevant policy period. Instead, NFICH argues that the

Policy includes an exclusionary clause which negates coverage. [ECF No. 15, PageID.454]. NFICH further asserts that the Policy is void under a fraud exclusion. Id. at PageID.455. The Policy provides that NFICH “will pay for direct physical loss or damage

to Covered Property at the premises described in the Declarations caused by or resulting from a Covered Cause of Loss. [ECF No. 15-2, PageID.480]. Covered Property includes buildings and business personal property. Id. The Policy limits

Covered Causes of Loss: 4. Limitations a.

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Related

Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Eileen A. Logan v. Denny's, Inc.
259 F.3d 558 (Sixth Circuit, 2001)
Auto-Owners Insurance v. Churchman
489 N.W.2d 431 (Michigan Supreme Court, 1992)
Heniser v. Frankenmuth Mutual Insurance
534 N.W.2d 502 (Michigan Supreme Court, 1995)
Clevenger v. Allstate Insurance
505 N.W.2d 553 (Michigan Supreme Court, 1993)
Estate of Eugene Wayne Hunt v. Roger Drielick
496 Mich. 366 (Michigan Supreme Court, 2014)

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