Harold Barnett v. Columbia Maintenance Company, Amco Insurance Company and Depositors Insurance Company

CourtMissouri Court of Appeals
DecidedJune 29, 2021
DocketED109008
StatusPublished

This text of Harold Barnett v. Columbia Maintenance Company, Amco Insurance Company and Depositors Insurance Company (Harold Barnett v. Columbia Maintenance Company, Amco Insurance Company and Depositors Insurance Company) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harold Barnett v. Columbia Maintenance Company, Amco Insurance Company and Depositors Insurance Company, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION THREE

HAROLD BARNETT, ) No. ED109008 ) Respondent, ) ) vs. ) ) Appeal from the Circuit Court COLUMBIA MAINTENANCE ) of the City of St. Louis COMPANY, et al., ) ) Respondents, ) ) Honorable Christopher McGraugh AMCO INSURANCE COMPANY ) and ) DEPOSITORS INSURANCE ) COMPANY ) ) Appellants. ) Filed: June 29, 2021

AMCO Insurance Company and Depositors Insurance Company (collectively “Insurers”)

appeal the circuit court’s order denying their motion to intervene in a proceeding to confirm an

arbitration award. Insurers sought to contest confirmation of the award, which was entered in

favor of Harold Barnett and against Insurers’ policy holders. Finding that the circuit court did

not err, and that certain of Insurers’ points are not properly before this Court, we affirm.

Factual and Procedural Background

Terminated from his job, Barnett sued his employer, Columbia Maintenance Company,

and William Hausman, the president and sole owner of Columbia Maintenance Company

(collectively “Defendants”), alleging violations of the Missouri Human Rights Act, as well as negligent infliction of emotional distress (“MHRA Action”). Insurers, who had issued

commercial general liability and umbrella polices to Defendants, denied coverage and refused to

defend Defendants. Insurers then filed a declaratory judgment action in federal court, seeking a

declaration that under the terms, conditions, and exclusions of Defendants’ policies, Insurers had

no duty to defend or to indemnify Defendants against Barnett’s MHRA Action.

After Insurers denied coverage and refused to defend Defendants, Barnett and Defendants

entered into a contract pursuant to Section 537.065, which in part limited recovery to insurance

proceeds (“537 Agreement”). Barnett notified Insurers of this contract on August 13, 2019. Five

days later, Insurers moved to intervene in the MHRA Action. The circuit court granted

intervention, and requested that the parties file memorandums concerning the extent to which

Insurers could conduct discovery and participate in trial. After receiving those memorandum,

the circuit court issued an order, dated October 4, 2019, in which the court stated that Insurers

“must accept this lawsuit as they find it at the time of their intervention,” and then ordered that

Insurers “have the same rights and responsibilities as any other party to this litigation, which

includes conducting discovery and participating in trial” (“October 2019 Order”).

Barnett dismissed the MHRA Action, without prejudice, on January 30, 2020, and

proceeded to binding arbitration with Defendants. Insurers were extended invitations to

participate in that arbitration, but declined to do so. The arbitrator issued his award on April 29,

2020, in favor of Barnett and against Defendants in the total amount of $11,437,009.90

(“Arbitration Award”). The arbitrator described Defendants’ actions as “one of the most

egregious and blatant Missouri Human Rights case violations” that the arbitrator had ever seen.

Barnett filed his application to confirm the award with the circuit court on May 1, 2020

2 (“Confirmation Proceeding”). Defendants responded, stating they had no objection to judgment

being entered on the award.

Insurers moved to intervene in the Confirmation Proceeding on May 8, 2020. Insurers

sought to intervene both as of right and by permissive intervention, pursuant to Rule 52.12, to

contest confirmation of the Arbitration Award (“Motion to Intervene”). They also filed a motion

to deny and/or dismiss the application for approval of the Arbitration Award on May 19, 2020

(“Motion to Dismiss”). The circuit court denied Insurers’ Motion to Intervene.

Insurers now advance nine points on appeal, alleging the circuit court erred in denying

intervention, and in denying or implicitly denying their Motion to Dismiss. We address each

point, but note that the issues raised by Insurers have largely been decided by Britt v. Otto, 577

S.W.3d 133 (Mo. App. W.D. 2019), Aguilar v. GEICO Cas. Co., 588 S.W.3d 195 (Mo. App.

W.D. 2019), and this Court’s recent decision, Loveland v. Austin, ED108859, 2021 WL1374010

(Mo. App. E.D. April 13, 2021).

Discussion

Points I and II: Intervention of Right

In their first two points on appeal, Insurers allege the circuit court misapplied Rule

52.12(a) in denying their Motion to Intervene in the Confirmation Proceedings as a matter of

right.1 Rule 52.12(a) states:

Intervention of Right. Upon timely application anyone shall be permitted to intervene in an action: (1) when a statute of this state confers an unconditional right to intervene or (2) when the applicant claims an interest relating to the property or transaction that is the subject of the action and the applicant is so situated that the disposition of the action may as a practical matter impair or impede the applicant’s ability to protect that interest, unless the applicant’s interest is adequately represented by existing parties.

1 For clarity, we address Points I and II out of order.

3 Insurers claim a right to intervention pursuant to Rule 52.12(a)(1) because an unconditional right

to do so is conferred by Section 537.065.2. Insurers claim a right to intervene pursuant to Rule

52.12(a)(2) because they had an interest in the Confirmation Proceeding and were so situated

that disposition of the Confirmation Proceeding impaired or impeded their ability to protect their

interests, which were not represented by the existing parties.

We address each claim in turn. In reviewing the circuit court’s denial of intervention as

of right, we consider the facts in the light most favorable to the court’s judgment.” Britt, 577

S.W.3d at 136 n.3 (internal quotation omitted). We will affirm the circuit court’s decision unless

there is no substantial evidence to support it, it is against the weight of the evidence, or it

erroneously declares or applies the law. State ex rel. Koster v. ConocoPhillips Co., 493 S.W.3d

397, 403 (Mo. banc 2016); see also Britt, 577 S.W.3d at 139.

Intervention as a Matter of Right Pursuant to Rule 52.12(a)(1)

Insurers claim they were entitled to intervene in the Confirmation Proceeding as a matter

of right pursuant to Rule 52.12(a)(1) because Section 537.065.2 conferred the unconditional right

to do so. Section 537.065.1 allows any person with an unliquidated claim for damages to enter

into a contract with a tortfeasor to limit the tort-feasor’s liability for a judgment to specified

assets, including insurance contracts. Britt, 577 S.W.3d at 140; see also, Schmitz v. Great Am.

Assurance Co., 337 S.W.3d 700, 709 (Mo. banc 2011). The right to enter into a section

537.065.1 contract limiting the tort-feasor’s liability to an insurance contract is conditioned on

the tort-feasor’s insurer being afforded the opportunity to defend the tort-feasor and refusing to

do so without reservation. Britt, 577 S.W.3d at 140. Section 537.065.2 then describes when a

judgment can be entered against a tort-feasor who has entered into a Section 537.065.1 contract:

Before a judgment may be entered against any tort-feasor after such tort-feasor has entered into a contract under this section, the insurer or insurers shall be

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Harold Barnett v. Columbia Maintenance Company, Amco Insurance Company and Depositors Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harold-barnett-v-columbia-maintenance-company-amco-insurance-company-and-moctapp-2021.