James E. Berry v. State Farm Mutual Automobile Insurance Company

CourtSupreme Court of Delaware
DecidedDecember 18, 2025
Docket155, 2025
StatusPublished

This text of James E. Berry v. State Farm Mutual Automobile Insurance Company (James E. Berry v. State Farm Mutual Automobile Insurance Company) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James E. Berry v. State Farm Mutual Automobile Insurance Company, (Del. 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

JAMES E. BERRY, § § No. 155, 2025 Plaintiff Below, § Appellant, § Court Below: Superior Court § of the State of Delaware v. § § C.A. No. N24C-09-033 STATE FARM MUTUAL § AUTOMOBILE INSURANCE § COMPANY § § Defendant Below, § Appellee. §

Submitted: November 12, 2025 Decided: December 18, 2025

Before SEITZ, Chief Justice; VALIHURA, and LEGROW, Justices.

ORDER

After consideration of the parties’ briefs and the record on appeal, it appears

to the Court that:

(1) James Berry, a Maryland resident, appeals from the Superior Court’s

order dismissing his complaint against State Farm Mutual Automobile Insurance

Company (“State Farm”) for lack of personal jurisdiction. Berry was injured in an

automobile collision in Delaware and sought underinsured motorist (“UIM”)

benefits under a Maryland automobile policy issued to him by State Farm. The

Superior Court held that Delaware’s long-arm statute, 10 Del. C. § 3104(c), does not confer specific jurisdiction over State Farm for Berry’s first-party UIM claim.1 We

affirm the dismissal of Berry’s complaint.

(2) On December 6, 2021, Berry was injured in an automobile accident in

Delaware. At the time of the accident, Berry resided in Maryland, and his vehicle

was insured under a Maryland State Farm policy that provided UIM coverage for

accidents occurring anywhere in the United States. The tortfeasor’s insurer paid its

$25,000 policy limit to settle Berry’s claims. State Farm consented to that settlement

and acknowledged Berry’s right to pursue a UIM claim under his policy. Berry then

filed this action in the Superior Court seeking UIM benefits, and State Farm moved

to dismiss for lack of personal jurisdiction. The Superior Court granted the motion,

relying primarily on Eaton v. Allstate Property & Casualty Insurance Co. to

conclude that Berry’s claim arose from an out-of-state insurance contract rather than

any tortious conduct by State Farm in Delaware.2

(3) We review issues of personal jurisdiction de novo.3 Berry bears the

burden of establishing a statutory basis for jurisdiction.4 Delaware courts apply a

two-step analysis to determine whether they may validly exercise jurisdiction over

1 Berry v. State Farm Mut. Auto. Ins. Co., 2025 WL 986819, at *3 (Del. Super. Apr. 2, 2025). 2 Id. at *2 (relying on Eaton v. Allstate Property & Casualty Ins. Co., 2021 WL 3662451 (Del. Super. Apr. 28, 2021)). 3 Genuine Parts Co. v. Cepec, 137 A.3d 123, 129 (Del. 2016). 4 AeroGlobal Capital Management, LLC v. Cirrus Industries, Inc., 871 A.2d 428, 437 (Del. 2005).

2 a party. First, the plaintiff must show that the defendant’s conduct falls within

Delaware’s long-arm statute; only if that showing is made do we consider whether

the exercise of jurisdiction comports with due process.5 Because we conclude that

Section 3104(c) does not confer jurisdiction over State Farm in this case, we do not

reach the constitutional question.

(4) Berry first argues that Section 3104(c)(3) confers specific jurisdiction

because his UIM claim “arises from” a tortious injury in Delaware and because State

Farm “stands in the shoes” of the tortfeasor.6 We reject that argument. As the Eaton

court correctly recognized, a UIM claim against one’s own insurer is a first-party

contract dispute, not a tort claim.7 The tortfeasor’s liability has been resolved by

settlement; the remaining controversy concerns State Farm’s alleged failure to

perform its obligations under a Maryland policy negotiated and issued outside

Delaware. Section 3104(c)(3) may extend to liability insurers that agree to defend

5 LaNuova D & B, S.p.A. v. Bowe Co., Inc., 513 A.2d 764, 768–69 (Del. 1986); Waters v. Deutz Corp., 479 A.2d 273, 276 (Del. 1984). 6 Appellant’s Opening Br. at 13. 7 Eaton, 2021 WL 3662451, at *2–3. In Eaton, a North Carolina driver insured by a North Carolina policy issued by Allstate sought UIM benefits from her insurer after she was injured in an accident in Delaware. The Superior Court concluded that it lacked specific jurisdiction under Section 3104(c)(3) because the “the basis of Plaintiff's claim against Allstate is not the vehicular accident, but rather the contractual obligation owed by Allstate.” Id. at *2. Even though the injury happened in Delaware, the insurer itself committed no act in Delaware that caused the injury—its obligations were defined by a contract made out-of-state, with “no germane connection to Delaware” beyond the fortuity of the accident’s location. Id. at *3.

3 and indemnify a tortfeasor for a Delaware accident,8 but it does not extend to first-

party claims for UIM or no-fault benefits.9 Berry’s claim sounds in contract, not

tort, and therefore falls outside § 3104(c)(3).

(5) Berry next urges us to apply a “dual jurisdiction” theory by combining

Sections 3104(c)(1) and (c)(4), arguing that State Farm’s nationwide auto policies

and its broader business presence in Delaware evince an intent to serve the Delaware

market sufficient to support jurisdiction.10 Delaware courts have only applied “dual

jurisdiction” theory in cases relating to manufactured products—the sale of wiper

blades,11 heart rate monitors,12 tablet computers,13 cable products,14 power supply

8 See, e.g., Tri-State Motor Transit Co. v. Intermodal Transp., Inc., 1991 WL 1172907, at *9 (Del. Super. 2002) (holding that an insurance guaranty association was subject to personal jurisdiction under Section 3104(c)(3) because the association had “stepp[ed] into the shoes” of an insolvent insurer, who had itself stepped into the shoes of the original tortfeasor); State Farm Mut. Auto. Ins. Co. v. Dann, 794 A.2d 42, 47–48 (Del. Super. 2002) (extending personal jurisdiction to a tortfeasor’s out-of-state insurer). 9 See, e.g., Donaldson v. Progressive Advanced Ins. Co., 2022 WL 951260, at *2 (Del. Super. Mar. 29, 2022), aff’d, 2022 WL 17087831 (Del. Nov. 21, 2022) (denying personal jurisdiction over a complaint seeking UIM benefits because “even if an insured was in an accident in Delaware, the basis of their claim against their insurance company is not for the accident, it is for the contractual obligations the insured is owed”); Uribe v. Maryland Auto. Ins. Fund, 2015 WL 3536574, at *3 (Del. May 21, 2015) (holding that an out-of-state insurer providing first-party benefits to its insured was not subject to personal jurisdiction merely because the accident occurred here). 10 Appellant’s Opening Br. at 26. 11 Robert Bosch LLC v. Alberee Prods., Inc., 70 F. Supp. 3d 665, 678–79 (D. Del. 2014). 12 Polar Electro Oy v. Suunto Oy, 829 F.3d 1343, 1352 (Fed. Cir. 2016). 13 Graphics Props. Holdings, Inc. v. ASUS Computer Int’l, 70 F. Supp. 3d 654, 660 (D. Del. 2014). 14 Belden Technologies, Inc. v. LS Corp., 829 F. Supp. 2d 260, 268 (D. Del. 2010).

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James E. Berry v. State Farm Mutual Automobile Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-e-berry-v-state-farm-mutual-automobile-insurance-company-del-2025.