Great American Insurance Company v. Dolese Bros Co

District Court, W.D. Oklahoma·Decided October 3, 2024·No. 5:23-cv-01013·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

GREAT AMERICAN INSURANCE ) COMPANY, an Ohio Corporation, ) ) Plaintiff, ) ) v. ) No. CIV-23-1013-R ) DOLESE BROS. CO., an Oklahoma ) Corporation; and JENNIFER WITTE, ) as Personal Representative of the Estate of ) Neil Perry Witte, deceased, a citizen of ) Oklahoma, ) ) Defendants. )

ORDER Before the Court is Defendant Dolese Bros. Co.’s Motion to Dismiss and/or to Decline Jurisdiction [Doc. 10] over Plaintiff Great American Insurance Co.’s Complaint for Declaratory Judgment [Doc. 1]. This matter was stayed pending resolution of Great American’s petition to the Oklahoma Supreme Court as part of the State Litigation seeking an extraordinary writ to prevent the state district court from hearing Dolese’s Third-Party Petition [Doc. 39]. The Oklahoma Supreme Court denied Great American’s request [Doc. 41-1]. Accordingly, this Court may now revisit the present Motion, which has been fully briefed by the parties [Docs. 18, 22, 27] and is ripe for review. For the reasons set forth below, Dolese’s Motion is GRANTED. I. Background This case stems from a wrongful death action filed in the District Court of Cleveland County, Oklahoma (“State Litigation”).1 Dolese was the only named defendant in the State

Litigation and held multiple insurance policies, including a policy with Great American [Doc. 10, at p. 2]. Under Dolese’s insurance arrangement, Great American was a secondary insurer—that is, its obligations would only trigger upon the exhaustion of the limits of Great American’s primary insurer, Travelers [Doc. 10, at p. 3]. As trial approached, the likelihood of an adverse judgment against Dolese became

increasingly likely [Doc. 18-6, at p. 4]. Accordingly, Dolese’s counsel escalated negotiations with the plaintiff’s counsel regarding a “High-Low” agreement (the “Agreement”) that would set both a ceiling and a floor on Dolese’s liability [Doc. 18-6, at pp. 1-3]. Throughout the negotiations period, Dolese’s counsel informed the insurance

carriers of both the status of negotiations, as well as the opinion that the Agreement was necessary to avoid a significant damages award [Doc. 18-6, at p. 2]. Great American never agreed to the terms proposed by the parties [Doc. 18-3]. Left with little time, Dolese entered into the Agreement with the plaintiff without Great American’s consent [Docs. 18-1, 18- 3]. Per the terms of the Agreement, Dolese’s liability was set at a minimum of $2 million

and a maximum of $20 million, and the rights to a jury trial and appeal were waived [Doc. 18-1].

1 Jennifer Witte, as Personal Representative of the Estate of Neil Percy Witte, Deceased v. Dolese, et al., Case No. CJ-2020-54. In the bench trial that followed Dolese was found liable, and the trial judge awarded the plaintiff $58.8 million [Doc. 18, at p. 1]. While this award was capped at $20 million

pursuant to the Agreement, it was sufficient to trigger Great American’s indemnification responsibilities under the policy [Doc. 18, at pp. 1-2]. Later that day, Great American filed this action seeking a declaration that Dolese’s consummation of the Agreement without its consent was a breach of contract that absolved it of its duty to indemnify [Doc. 18, at p. 2]. Following Great American’s filing, Dolese sought leave from the state court to file a third-party petition in the original State Litigation, which was granted [Doc. 10, p. 5].

Shortly thereafter, Dolese filed its Third-Party Petition against Great American in state court under two theories. First, Dolese alleged that Great American breached its contract by failing to indemnify Dolese for the portion of the judgment that fell within its policy limits. Second, Dolese claimed that Great American breached its duty of good faith and fair dealing by refusing to consent to the Agreement [Doc. 22-1]. Dolese then filed the

present Motion requesting this Court decline jurisdiction over the Declaratory Action due to the pending status of the Third-Party Petition in state court [Doc. 10, at p. 1]. Meanwhile, Great American removed the Third-Party Petition to this Court, but the action was remanded for procedural deficiencies [Doc. 18-4]. In response, Great American filed an extraordinary writ with the Oklahoma Supreme Court to require dismissal of

Dolese’s Third-Party Petition, which was denied [Docs. 38, 41-1]. II. Legal Standard “[A]ny court of the United States…may declare the rights and other legal relations of any interested party seeking such declaration[.]” 28 U.S.C. § 2201(a). However, a “district court is not obliged to entertain every justiciable declaratory judgment claim brought before it.” State Farm Fire & Cas. Co. v. Mhoon, 31 F.3d 979, 982 (10th Cir. 1994).

Rather, “[w]hether to entertain a justiciable declaratory judgment action is a matter committed to the sound discretion of the trial court. Kunkel v. Cont’l Cas. Co., 866 F.2d 1269, 1273 (10th Cir. 1989). In determining whether to hear a declaratory judgment action, a court should ask whether a judgment would “(1) clarify or settle the legal relation in issue and (2) terminate or afford relief from the uncertainty giving rise to the proceeding.” Id. at 1275 (internal

citations omitted). If the answer to both inquiries is “yes,” the case should proceed; if not, the trial court should decline jurisdiction. Mhoon, 31 F.3d at 983. While these two questions act as the lodestar for a court’s determination, more probing is required. As set forth in Mhoon, when deciding whether to exercise or to decline jurisdiction, the trial court must consider the following factors:

[1] whether a declaratory action would settle the controversy; [2] whether it would serve a useful purpose in clarifying the legal relations at issue; [3] whether the declaratory remedy is being used merely for the purpose of “procedural fencing” or “to provide an arena for a race to res judicata; [4] whether 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.

Id. (internal citations omitted). III. Discussion A. Whether a Declaratory Action Would Settle the Controversy This dispute has two distinct parts. The first part is Great American’s Declaratory Action seeking a declaration that Dolese breached the contract by entering into the Agreement without Great American’s consent, and thus Great American is not required to indemnify Dolese [Doc. 1, at p. 5]. The second part is Dolese’s Third-Party Petition in state

court which claims that Great American is in breach of contract for failure to pay the portion of the judgment covered by its policy, as well as that Great American violated the duty of good faith and fair dealing when it refused to consent to the Agreement [Doc. 22- 1]. A declaratory judgment by this Court would settle only one of the two parts. A declaration that Great American either is or is not responsible for the portion of the

judgment would settle the breach of contract portion of the dispute in both the Declaratory Action and the Third-Party Petition. However, this determination would do nothing to settle the second—and wholly separate—bad faith claim in the Third-Party Petition. The bad faith claim has no relation to whether Dolese breached the contract by entering into the Agreement without Great American’s consent. Instead, it focuses on whether Great

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

Great American Insurance Company v. Dolese Bros Co, (W.D. Okla. 2024).

Great American Insurance Company v. Dolese Bros Co (Great American Insurance Company v. Dolese Bros Co) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related