HG Jones, LLC v. Jordan Howell

CourtCourt of Appeals of Tennessee
DecidedMay 21, 2025
DocketM2024-00654-COA-R3-CV
StatusPublished

This text of HG Jones, LLC v. Jordan Howell (HG Jones, LLC v. Jordan Howell) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HG Jones, LLC v. Jordan Howell, (Tenn. Ct. App. 2025).

Opinion

05/21/2025 IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE January 9, 2025 Session

HG JONES, LLC v. JORDAN HOWELL ET AL.

Appeal from the Circuit Court for Rutherford County No. 80775 Darrell Scarlett, Judge ___________________________________

No. M2024-00654-COA-R3-CV ___________________________________

At issue is a purely legal question, the interpretation and application of “other insurance” clauses in two respective insurance policies that determine which policy provides primary coverage and which provides excess coverage to the property management company in the underlying premises liability action. HG Jones, LLC, d/b/a Real Property Management Solutions (“HG Jones”), is the manager of property owned by Jordan Howell (“Mr. Howell”). Both are defendants in the underlying premises liability action. HG Jones is the named insured under a Commercial General Liability Policy issued by Auto-Owners Insurance Company (“Auto-Owners”). Mr. Howell is the named insured in a Dwelling and Personal Property Coverage Policy issued by The Cincinnati Insurance Company (“Cincinnati”). In this action, HG Jones sought a declaration that Cincinnati had a duty to defend and indemnify HG Jones in the premises liability action as the primary insurer because HG Jones qualifies as an “insured” as that term is defined in the Cincinnati policy. For its part, Cincinnati claimed that its policy only provides excess coverage over HG Jones Auto-Owners’ policy based, inter alia, on the “other insurance” clauses in the two policies and the fact that HG Jones was not specifically listed as an “additional insured” under the Cincinnati policy. The parties filed competing motions for judgment on the pleadings. The trial court determined that there was no legal distinction between the terms “insured” and “additional insured” and HG Jones was an insured under the Cincinnati policy. Therefore, the court ruled that Cincinnati had the primary duty to defend and indemnify HG Jones in the premises liability action. Cincinnati appeals. We have determined that the “other insurance” clauses set forth in the two policies must be deemed void because they are mutually repugnant. Because HG Jones is the named insured under the Auto-Owners’ policy and HG Jones is an insured under the Cincinnati policy by virtue of the definition of an “insured” under that policy, both policies afford HG Jones primary coverage. Thus, the duty to defend and indemnify HG Jones in the premises liability action must be prorated between Cincinnati and Auto-Owners. Accordingly, we reverse the judgment of the trial court and remand for further proceedings consistent with this opinion.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Circuit Court Reversed and Remanded

FRANK G. CLEMENT JR., P.J., M.S., delivered the opinion of the Court, in which ANDY D. BENNETT and JEFFREY USMAN, JJ., joined.

E. Jason Ferrell and Hannah J. Leifel, Nashville, Tennessee, for the appellant, The Cincinnati Insurance Company.

James Barger, Murfreesboro, Tennessee, for the appellee, HG Jones, LLC, d/b/a Real Property Management Solutions.

OPINION

FACTS AND PROCEDURAL HISTORY

In March 2021, Laila Ali (“Ms. Ali”) allegedly slipped and fell while walking down the front steps of a residential rental property1 owned by Jordan Howell and managed by HG Jones. In February 2022, Ms. Ali sued both Mr. Howell and HG Jones in the underlying rental property slip and fall case of Laila Ali v. Jordan Howell, HG Jones LLC, Real Property Management Solutions, Rutherford County Circuit Court, Case No. 79491.

Prior to Ms. Ali’s fall, HG Jones and Mr. Howell entered into a property management contract (“the Management Contract”) for the management of Mr. Howell’s rental property. The Management Contract reads, in pertinent part:

HOLD HARMLESS & INDEMNITY-HOMEOWNER’S POLICY: The Owner agrees to hold the Manager its agent, independent contractors, and employees, harmless from all damage suits or claims in connection with the management of said property, except in the case of gross negligence or illegal act by the Manager, and from all Liability for injuries to person or property suffered or sustained by any person whomsoever. Owner agrees to carry, at Owner’s own expense, public liability insurance (homeowner’s insurance) in sufficient amounts to protect the interest of parties hereto, and policies shall be written to protect the Manager in the same manner and the same extent as the Owner. Owner shall have Manager designated on said policy as an additional insured. Owner agrees to indemnify Manager for any damages suffered as a result of any lapse in or failure by Owner to maintain insurance coverage. Owner agrees to indemnify and hold Manager harmless from any and all claims, causes of action, suits and damages arising out of or relating to the selection of a vendor to perform work on the property.

1 The property is located at 1824 Herald Lane, Murfreesboro, Tennessee.

-2- Pursuant to the Management Contract, HG Jones made a formal demand to Mr. Howell that he indemnify and defend HG Jones in the underlying lawsuit brought by Ms. Ali. When Mr. Howell and his insurer Cincinnati refused, HG Jones instituted the instant action requesting the court to declare that Mr. Howell was obligated to “indemnify and hold [HG Jones] harmless from the pending action in Rutherford County Circuit Court Case #79491, pursuant to the [Management Contract].”2

On July 19, 2023, HG Jones amended its complaint to add Cincinnati as a defendant. The amended petition sought a declaration that Cincinnati was the primary insurer of HG Jones and, as such, had a duty to defend HG Jones in the underlying litigation. HG Jones requested that Cincinnati pay its reasonable and necessary attorney’s fees and costs incurred to date in the underlying litigation. Cincinnati responded by filing an answer as well as a counterclaim.

At the time of Ms. Ali’s fall, Cincinnati insured Mr. Howell under a Dwelling and Personal Property Coverage Policy while Auto-Owners provided coverage to HG Jones under a Commercial General Liability Policy. Both policies contained “other insurance” clauses. Cincinnati’s “other insurance” clause provided that its coverage was excess unless another valid policy was written specially to afford excess coverage, in which case its policy would be primary. Auto-Owners’ “other insurance” clause provided that it was primary except when, inter alia, the insured had been added as an “additional insured” on “any other primary insurance covering liability for damages arising out of the premises or operations[.]” While HG Jones was not specifically listed on the Cincinnati policy as an “insured”, a “named insured”, or an “additional insured,” it is undisputed that HG Jones qualified as an “insured” as that term is defined in the Cincinnati policy because HG Jones was acting as Mr. Howell’s “real estate manager” when Ms. Ali’s claim accrued.3 In August 2023, Cincinnati filed an answer and counterclaim contending that it had no duty to defend HG Jones. Cincinnati admitted that HG Jones qualified as an “insured” under its policy; however, it claimed that being an “insured” is distinct from being an “additional insured.” Because HG Jones had not been specifically added as an “additional insured” under its policy, Cincinnati claimed that its policy was excess while Auto- Owners’ policy was primary. HG Jones countered arguing that that the language of Cincinnati’s policy makes no distinction between “insured” and “additional insured” for purposes of excess or primary coverage determination. Because HG Jones qualified as an insured under the Cincinnati

2 The contractual claims against Mr. Howell are not at issue in this appeal.

3 Cincinnati’s policy defines “insured” as including “Any person . . .

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Bluebook (online)
HG Jones, LLC v. Jordan Howell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hg-jones-llc-v-jordan-howell-tennctapp-2025.