INTERSTATE 10 PARTNERS, LLC v. BERKLEY NATIONAL INSURANCE COMPANY

CourtDistrict Court, M.D. Tennessee
DecidedMarch 21, 2026
Docket3:23-cv-01233
StatusUnknown

This text of INTERSTATE 10 PARTNERS, LLC v. BERKLEY NATIONAL INSURANCE COMPANY (INTERSTATE 10 PARTNERS, LLC v. BERKLEY NATIONAL INSURANCE COMPANY) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
INTERSTATE 10 PARTNERS, LLC v. BERKLEY NATIONAL INSURANCE COMPANY, (M.D. Tenn. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

INTERSTATE 10 PARTNERS, LLC, ) ) Plaintiff, ) ) NO. 3:23-cv-01233 v. ) ) JUDGE RICHARDSON BERKLEY NATIONAL INSURANCE ) COMPANY, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pending before the Court is a “Motion For Leave To File Motion For Partial Summary Judgment And Request For Certification Of Questions To Tennessee Supreme Court” (Doc. No. 42, “Motion”) filed by Defendant, Berkley National Insurance Company. Via the Motion, Defendant seeks leave to file a motion for partial summary judgment concerning the damages that Plaintiff would be able to collect from Defendant. Specifically, via its motion for partial summary judgment, Defendant intends to request that the “Court grant partial summary judgment for [Defendant], holding that Tennessee’s bad-faith statute, T.C.A. § 56-7-105[(a)], prov[id]es the exclusive extra-contractual remedy in insurance-coverage cases against insurers for refusal to pay,”1 and that the Court “grant partial summary judgment for [Defendant], holding that

1 Defendant’s Motion, in seeking leave to file a motion for partial summary judgment on the damages that Plaintiff may be able to collect, is framed in terms of whether T.C.A. § 56-7-105 generally (rather than a specific subsection of that T.C.A. section) provides the exclusive extra-contractual remedy in insurance- coverage cases against insurers for refusal to pay. However, in Defendant’s opening brief (Doc. No. 43 at 3) and reply (Doc. No. 49 at 4) in support of the Motion, as well as in Defendant’s proposed memorandum (Doc. No. 42-4 at 11) in support of its proposed motion for summary judgment (Doc. No. 42-1), Defendant refers specifically to whether T.C.A. § 56-7-105(a) provides the exclusive extra-contractual remedy in insurance-coverage cases. Thus, the Court discerns that, in the Motion, Defendant intended to refer to whether T.C.A. § 56-7-105(a) specifically (rather than T.C.A. § 56-7-105 generally) provides the exclusive Tennessee’s statutory cap on punitive damages, T.C.A. § 29-39-104, does not violate the Tennessee Constitution’s right to a trial by jury.” (Doc. No. 42 at 1-2). In connection with this request, Defendant has filed a proposed motion for partial summary judgment (Doc. No. 42-1, “Proposed Motion for Partial Summary Judgment”), a proposed memorandum of law (Doc. No.

42-4) in support of the Proposed Motion for Partial Summary Judgment, and a proposed statement of facts (Doc. No. 42-2) along with an exhibit thereto. (Doc. No. 42-3). Alternatively to requesting leave to seek partial summary judgment, Defendant requests that the Court certify two questions to the Tennessee Supreme Court, namely: (1) “Does Tennessee’s bad-faith statute, T.C.A. § 56-7-105(a), provide the exclusive extra-contractual remedy against an insurer for breach of an insurance policy?”; and (2) “If Tennessee’s bad-faith statute does not provide the exclusive extra-contractual remedy against an insurer for breach of an insurance policy, does Tennessee’s statutory cap on punitive damages, T.C.A. § 29-39-104, violate the right to a jury trial under the Tennessee Constitution?” (Doc. No. 42 at 2). Defendant has filed an opening brief (Doc. No. 43) in support of the Motion, Plaintiff,

Interstate 10 Partners, LLC, has filed a response (Doc. No. 48) in opposition to the Motion, and Defendant has filed a further reply (Doc. No. 49) in support of the Motion. For the reasons discussed herein, Defendant’s Motion is DENIED in its entirety. BACKGROUND The instant action arises out of an insurance coverage dispute. Plaintiff “is a Tennessee limited liability company with its principal office located in Nashville, Tennessee.” (Doc. No. 17

extra-contractual remedy in insurance-coverage cases against insurers for refusal to pay and will analyze the Motion accordingly. at ¶ 1).2 Defendant “is an insurance company organized under the laws of the state of Iowa, with its principal office located in Urbandale, Iowa.” (Id. at ¶ 2). This action arises out of an insurance dispute concerning a hotel building and the surrounding area in Nashville, Tennessee (“Insured Premises”) in which Plaintiff had an insurable interest pursuant to the terms of an insurance

contract (the “Policy”) entered into with Defendant. (Id. at ¶¶ 5-8, 14). The Insured Premises were damaged as a result of extreme weather that occurred in March 2020. (Id. at ¶¶ 15-16). Plaintiff contends that Defendant did not pay the amounts owed to Plaintiff under the Policy after the damage to the Insured Premises, and based on that contention brings a single claim for breach of contract against Defendant. (Id. at ¶¶ 47-57). Plaintiff seeks various forms of damages from Defendant, including compensatory damages and an award of punitive damages. (Id. at 17). ANALYSIS Via the Motion, Defendant makes two requests. First, Defendant requests leave to file a motion for partial summary judgment: the Proposed Motion for Partial Summary Judgment. Second, Defendant seeks certification of two questions to the Tennessee Supreme Court. The Court

will address each of these requests in turn.3

2 In the Background section, the Court cites to the operative, amended complaint. (Doc. No. 17, “Amended Complaint”). For the purposes of the instant Motion, none of the facts alleged in the Amended Complaint are taken as true, and the Court provides them here merely for context to the instant Motion.

3 The Court notes here, as an initial matter, that it has little doubt that Tennessee state law applies to this action given that it is an action (seemingly, although the Amended Complaint does not state this explicitly) over which the Court may exercise jurisdiction solely based on diversity jurisdiction and concerning events that took place in Tennessee. See e.g., Beahm v. Auto Owners Ins. Co., No. 3:13-CV-160-JMH, 2013 WL 3976622, at *2 (E.D. Tenn. Aug. 2, 2013) (“Because this action is in this Court on the basis of diversity jurisdiction, state substantive law, and, thus, Tennessee law, applies.”). The parties likewise (as evidenced by the instant Motion) do not dispute that Tennessee state law governs this dispute. 1. Defendant’s Request for Leave to Seek Partial Summary Judgment As noted above, Defendant seeks leave to file a motion for partial summary judgment concerning the damages that Plaintiff may be able to collect from Defendant—the Proposed Motion for Partial Summary Judgment—wherein it will request that (1) the “Court grant partial

summary judgment for [Defendant], holding that Tennessee’s bad-faith statute, T.C.A. § 56-7- 105[(a)], prov[id]es the exclusive extra-contractual remedy in insurance-coverage cases against insurers for refusal to pay,” and (2) the Court “grant partial summary judgment for [Defendant], holding that Tennessee’s statutory cap on punitive damages, T.C.A.

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INTERSTATE 10 PARTNERS, LLC v. BERKLEY NATIONAL INSURANCE COMPANY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/interstate-10-partners-llc-v-berkley-national-insurance-company-tnmd-2026.