Forum Insurance v. Aviation Enterprises, Inc.

722 F. Supp. 1525, 1988 U.S. Dist. LEXIS 16889, 1988 WL 167417
CourtDistrict Court, W.D. Tennessee
DecidedMarch 15, 1988
DocketNo. 84-3032-4B
StatusPublished

This text of 722 F. Supp. 1525 (Forum Insurance v. Aviation Enterprises, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Forum Insurance v. Aviation Enterprises, Inc., 722 F. Supp. 1525, 1988 U.S. Dist. LEXIS 16889, 1988 WL 167417 (W.D. Tenn. 1988).

Opinion

ORDER ON PENDING MOTIONS

McRAE, Senior District Judge.

Plaintiff Forum Insurance Company (“Forum”) brought this declaratory judgment action seeking a determination of its liability under a contract of insurance. The suit arises from the August 11, 1984 crash of an aircraft insured by Forum and operated by defendant Aviation Enterprises, Inc. (“Aviation Enterprises”). Shortly after its takeoff, the aircraft lost power in one of its engines and struck a warehouse at the United States Department of Defense depot in Memphis. Plaintiff Forum asserts that because of an exclusion contained in the insurance contract, it is not liable for any damage to property owned by defendants United States and the United States Department of Defense. Forum also contends that the policy provides no coverage for the aircraft’s cargo, which was owned by Hughes Aircraft Company and insured by defendant Jeremy New Phillips and other underwriters at Lloyd’s, London and Companies.

In its Order on Pending Motions dated September 15, 1987, the Court granted defendant United States’ Motion for Summary Judgment, finding the policy exclusion relied upon by Forum inapplicable to that defendant’s damages claim. Forum is now before the Court on its Motion to Reconsider or, Alternatively, for Rule 54(b) Certification for immediate appeal. Defendant United States has submitted a response and that motion is ripe for decision. Plaintiff has also filed an Amended Motion for Partial Summary Judgment with respect to its potential liability to defendant Phillips for the value of the aircraft's cargo. A response to this motion has also been submitted, and it is likewise ripe for consideration. The Court will address each motion in turn.

Motion to Reconsider or, Alternatively for Rule 54(b) Certification

On September 15, 1987, the Court ruled that a coverage exclusion contained in the insurance contract was inapplicable, and thus ineffective, to bar Forum's liability for the property damage sustained by defendant United States. The exclusion at issue states:

Unless otherwise provided in the policy of insurance, the liability insurance afforded under this policy shall not apply to: ... (m) Any loss arising from operations with aircraft which, at takeoff, have not had inspections, maintenance, preventive maintenance, and alterations performed when required by the Federal Aviation Regulations....

(Emphasis added). Forum contends that there is an issue of fact as to whether required inspections and maintenance took place. Forum contends further that the word “loss” as it is used in the contract is ambiguous and that based upon its interpretation of the agreement, “loss” should be construed broadly so as to potentially eliminate its liability for damage to property on the ground which was struck by the aircraft.

[1527]*1527As the Court noted in its earlier ruling, however, the contract gives the term “loss” a clear and unambiguous meaning. In the policy section entitled “Definitions Applicable to All Policy Sections,” it provides: “ ‘Physical Damage’ means direct and acci-dential loss of or damage to the Insured Aircraft, hereinafter called loss, but does not include loss, of use or reduction in value, if any, after repairs have been made” (emphasis added). Thus, in nearly as unmistakable a manner as can be expressed, the contract states that where the word “loss” is used within its four corners, the reference is to “damage to the Insured Aircraft.”

Plaintiff argues “[i]t is clear that physical damage to aircraft is one type of loss, but nowhere does the policy say that loss only applies to physical damage to the insured’s aircraft.” Memorandum in Support of Plaintiff’s Motion to Reconsider at 2. That is so as far as it goes; however, nowhere else in the definitional section does the policy say or even suggest that other kinds of damage will be referred to as “loss.” Neither the definition of “Property Damage” nor the definition of “Bodily Injury” contain the phrase “hereinafter called loss.” Despite this, plaintiff argues that unless the phrase “hereinafter called loss” is stated in a form which would make it not only unnatural and unreasonable, but impossible, to understand it in any other way, it is ambiguous. This argument asks the Court to find an ambiguity where none exists. The phrase at issue is clear, neither the paragraph in which it is found nor the other definitional provisions state or suggest in any way that it should be construed other than in the manner in which such phrases are typically understood. The contract provides, and does not intimate otherwise, that “loss” refers exclusively to physical damage to the insured aircraft.

In any event, the rule is well established that ambiguity in an insurance policy must be construed against the insurer. Palmer v. State Farm Mutual Automobile Insurance Company, 614 S.W.2d 788, 789 (Tenn. 1981); see also, Transamerica Insurance Group v. Beem, 652 F.2d 668, 666 (6th Cir.1981). Plaintiff asserts that this rule should not be applied here because it did not draft the exclusion at issue. Plaintiff points out that the form of Standard Endorsement 5, which contains the exclusion, was dictated by the Civil Aeronautics Board (“CAB”). Plaintiff, however, did draft the definitional section at issue, and to the extent that existing policy definitions limited the scope of the exclusions more than CAB regulations required, plaintiff was free to modify the definitions’ content to reflect what it felt was intended and permissible.

Where an alleged ambiguity exists only because of the draftsmanship of the insurer, the mere fact that the plain and ordinary meaning of a portion of the policy not drafted by the insurer might be altered by portions of the policy which were drafted by it does not provide a basis for the Court to refuse to apply the usual rule regarding the interpretation of ambiguous language. Accordingly, even if the Court were to find ambiguity, it would have to resolve any such ambiguity in favor of coverage.

Plaintiff makes the further argument that the introductory phrase preceding the delineation of the specific exclusions heightens any ambiguity involving the meaning of the term “loss.” That phrase, quoted above, states: . “Unless otherwise provided in the policy of insurance, the liability insurance afforded under the policy shall not apply to: ... ” (emphasis added). Plaintiff focuses on the word “liability” and urges that the “usual interpretation of ‘liability insurance’ refers to third-party, not the insured’s, claims,” and that, therefore, to rely on a definition of loss which refers only to the insured’s claims would render the introductory phrase nonsensical. Thus, based upon this alleged “usual interpretation,” plaintiff asserts that the Court should refuse to apply the “technical” meaning it assigned to the word “loss” earlier in the contract.

First, it should be noted that simply because a phrase is alleged to have a usual definition, a Court is not bound to apply that definition in construing a contract which uses other terms whose contractually-established meanings would be rendered [1528]*1528absurd or meaningless if that phrase’s alleged usual definition were relied upon.

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Bluebook (online)
722 F. Supp. 1525, 1988 U.S. Dist. LEXIS 16889, 1988 WL 167417, Counsel Stack Legal Research, https://law.counselstack.com/opinion/forum-insurance-v-aviation-enterprises-inc-tnwd-1988.