Great West Casualty Co. v. Nationwide Agribusiness Insurance Co.

CourtCourt of Appeals for the Seventh Circuit
DecidedFebruary 11, 2026
Docket24-1259
StatusPublished
AuthorPryor

This text of Great West Casualty Co. v. Nationwide Agribusiness Insurance Co. (Great West Casualty Co. v. Nationwide Agribusiness Insurance Co.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Great West Casualty Co. v. Nationwide Agribusiness Insurance Co., (7th Cir. 2026).

Opinion

In the

United States Court of Appeals For the Seventh Circuit ____________________ Nos. 24-1258 & 24-1259 GREAT WEST CASUALTY CO., Plaintiff-Appellee, Cross-Appellant, v.

NATIONWIDE AGRIBUSINESS INSURANCE CO., and CONSERV FS, INC., Defendants-Appellants, Cross-Appellees,

and

TIMOTHY A. BRENNAN, as Administrator of the Estate of Pat- rick J. Brennan, deceased, Defendant. ____________________ Appeals from the United States District Court for the Northern District of Illinois, Eastern Division. No. 23-cv-2178 — Matthew F. Kennelly, Judge. ____________________

ARGUED SEPTEMBER 26, 2024 — DECIDED FEBRUARY 11, 2026 ____________________

Before EASTERBROOK, ST. EVE, and PRYOR, Circuit Judges. 2 Nos. 24-1258 & 24-1259

PRYOR, Circuit Judge. Great West Casualty Company (“Great West”) and Nationwide Agribusiness Insurance Company (“Nationwide”) collectively insured a tractor- trailer involved in an unfortunate collision with a passenger vehicle driven by Patrick J. Brennan. The side-impact collision killed Brennan, prompting his estate’s wrongful death suit against various entities in state court. The insurers agree that both of their policies provide coverage, but filed the underly- ing declaratory judgment action to determine which policy pays first. The district court concluded that the companies have equal payment priority. For the reasons provided below, we affirm. I. BACKGROUND A. Facts The auto accident underlying this case occurred on June 2, 2021, near Sycamore, Illinois. A tractor-trailer driven by Rob- ert D. Fisher collided with an SUV driven by Patrick J. Bren- nan, killing Brennan. Fisher was an agent of Deerpass Farms Trucking, LLC-II (“Deerpass Trucking”). Deerpass Trucking is an interstate motor carrier that pro- vides transportation services. It, however, owned neither the 2014 Kenworth tractor nor the 1989 Sunshine tanker trailer in- volved in the underlying collision. It leased the tractor from Deerpass Farms Services, LLC (“Deerpass Farms”) pursuant to an Independent Contractor Equipment Lease Agreement (“Deerpass Lease”), signed on August 1, 2020. And the trailer was owned by Conserv FS, Inc. (“Conserv”). Deerpass Truck- ing hauled cargo and empty trailers for Conserv pursuant to a Trailer Interchange Equipment Use Agreement (“Inter- change Agreement”), signed January 12, 2021. Nos. 24-1258 & 24-1259 3

The tractor and trailer were both insured with commercial liability insurance. Great West insured the tractor with a $1 million policy limit with the policyholder, Deerpass Trucking. Nationwide insured the trailer with a $2 million policy limit to Conserv. On October 12, 2021, Brennan’s estate brought a wrongful death suit in Illinois state court, eventually adding Fisher, Deerpass Trucking, Deerpass Services, and Conserv as de- fendants. On April 6, 2023, Great West sued Nationwide in federal court seeking a declaratory judgment precipitating this appeal. Before we elaborate on the district court proceed- ings, we briefly introduce the insurance contracts that lay the foundation for Great West and Nationwide’s dispute over their coverage responsibilities. B. The Insurance Policies Great West and Nationwide agree that each of their poli- cies cover Fisher, Deerpass Trucking, and Conserv. The Great West policy provided coverage with a $1 million limit per ac- cident or loss. The Great West policy covers Deerpass Truck- ing because Deerpass Trucking is the policyholder. The policy also insures anyone using a “covered auto” with Deerpass Trucking’s permission. Under Great West’s policy, an “insured” is defined as “[t]he owner or anyone else from whom you hire or borrow a covered ‘auto’ that is a ‘trailer’ while the ‘trailer’ is connected to another covered ‘auto’ that is a power unit, or, if not connected, is being used exclusively in your business.” The parties agree that the tractor was a “covered auto” under the Great West policy, that Fisher is “in- sured” because he was operating the tractor with the permis- sion of Deerpass Trucking, and that Conserv is “insured” 4 Nos. 24-1258 & 24-1259

because it owned the trailer coupled to the tractor. Thus, the Great West policy covers Deerpass Trucking (the policy- holder), as well as Conserv (the trailer owner) and Fisher (the operator). Nationwide’s policy similarly covers all three entities us- ing similar definitions used in the Great West policy. It covers Conserv as the policyholder. It also covers anyone “using with [Conserv’s] permission a covered ‘auto’” that Conserv owned, so both Deerpass Trucking and the operator, Fisher, were covered under the Nationwide policy as well. The Na- tionwide policy provided coverage with a $2 million limit per accident or loss. Both policies contemplate an insured’s ability to collect coverage payments from multiple insurers by distinguishing between “primary” coverage and “excess” coverage. The dis- tinction is simple but at the core of this case: when an entity is covered by two policies, the policy providing primary cover- age pays first (up to the policy limit). Only after the primary policy has paid does the excess coverage kick in. 1 To under- stand the parties’ coverage dispute, we examine the “Other Insurance” provisions from each policy. 1. Nationwide’s “Other Insurance” Section a. For any covered “auto” you own, this Coverage Form provides primary insurance. For any covered “auto” you don’t own, the in- surance provided by this Coverage Form is

1 See Sean Ross, Understanding Insurance vs. Excess Insurance vs. Reinsur-

ance, INVESTOPEDIA (Aug. 10, 2023), https://www.investopedia.com/arti- cles/personal-finance/081116/insurance-excess-insurance-and-reinsur- ance-whats-difference-all.asp. Nos. 24-1258 & 24-1259 5

excess over any other collectible insurance. However, while a covered “auto” which is a “trailer” is connected to another vehicle, the Covered Autos Liability Coverage this coverage Form provides for the “trailer” is: (1) Excess while it is connected to a motor vehicle you do not own; or (2) Primary while it is connected to a covered “auto” you own. Nationwide’s coverage is “excess” coverage because, as the parties agree, paragraph 5.a(1) of Nationwide’s “Other Insur- ance” provision applies here. This is because the policyholder, Conserv, owned a “covered auto”—the trailer—that was “connected to a motor vehicle [Conserv] do[es] not own”— the tractor. Next, we look at the relevant language from the “Other Insurance” section of the Great West policy. 2. Great West’s “Other Insurance” Section a. While any covered “auto” is hired or bor- rowed from you by another “motor carrier,” this Coverage Form’s Covered Autos Liability Coverage is: (1) Primary if a written agreement between you as the lessor and the other “motor car- rier” as the lessee requires you to hold the lessee harmless. (2) Excess over any other collectible insur- ance if a written agreement between you as the lessor and the other “motor carrier” as 6 Nos. 24-1258 & 24-1259

the lessee does not require you to hold the lessee harmless. b. While any covered “auto” is hired or bor- rowed by you from another “motor carrier” this Coverage Form's Covered Autos Liability Coverage is: (1) Primary if a written agreement between the other “motor carrier” as the lessor and you as the lessee does not require the lessor to hold you harmless, and then only while the covered “auto” is used exclusively in your business as a “motor carrier” for hire. (2) Excess over any other collectible insur- ance if a written agreement between the other “motor carrier” as the lessor and you as the lessee requires the lessor to hold you harmless. c.

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Great West Casualty Co. v. Nationwide Agribusiness Insurance Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/great-west-casualty-co-v-nationwide-agribusiness-insurance-co-ca7-2026.