James v. State Farm

2019 S.D. 31
CourtSouth Dakota Supreme Court
DecidedMay 29, 2019
Docket#28547-a-JMK
StatusPublished

This text of 2019 S.D. 31 (James v. State Farm) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James v. State Farm, 2019 S.D. 31 (S.D. 2019).

Opinion

#28547-a-JMK 2019 S.D. 31

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

LEROY L. JAMES, JR., Plaintiff and Appellee,

v.

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant and Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT PENNINGTON COUNTY, SOUTH DAKOTA **** THE HONORABLE ROBERT A. MANDEL Judge

JOHN STANTON DORSEY KIMBERLY PEHRSON of Whiting, Hagg, Hagg, Dorsey & Hagg, LLP Rapid City, South Dakota Attorneys for plaintiff and appellee.

HILARY L. WILLIAMSON of Fuller & Williamson, LLP Sioux Falls, South Dakota Attorneys for defendant and appellant.

**** CONSIDERED ON BRIEFS ON OCTOBER 1, 2018 OPINION FILED 05/29/19 #28547

KERN, Justice

[¶1.] Melissa Rivers rear-ended LeRoy James Jr., causing him personal

injury. State Farm insured both parties. Immediately following the accident, State

Farm paid a portion of James’s medical expenses under the medical payment

provisions of his policy. Acting on behalf of Rivers, State Farm then settled with

James. Once James released Rivers from liability, State Farm demanded James

use his settlement proceeds to reimburse it for paying his medical expenses under

his policy. James sued for declaratory relief, arguing State Farm had no right to

reimbursement or subrogation. The circuit court denied State Farm’s motion for

summary judgment and entered a judgment in favor of James. State Farm appeals.

We affirm.

Facts and Procedural History

[¶2.] The automobile accident occurred on July 22, 2016, on Highway 16

near Rapid City. At the time, State Farm insured both Rivers and James under

separate auto insurance policies. Rivers’s policy provided $100,000 in liability

coverage. James’s policy contained a $5,000 benefit for medical payments

coverage. 1 State Farm immediately paid $5,000 on James’ behalf to medical

services providers for treatment of James’s injuries.

1. James’s medical payment coverage provision provides: “The Medical Payment Coverage limit is shown on the Declarations Page under ‘Medical Payments Cover – Limit – Each person.’ This limit is the most we will pay for the medical expenses and funeral expenses combined, incurred by or on behalf of any one insured as a result of any one accident . . . .” (Emphasis in original.) -1- #28547

[¶3.] Ultimately, James settled his claim against Rivers. Rivers did not

personally fund any of the settlement proceeds. Instead, State Farm paid James

$43,000 on Rivers’s behalf in exchange for a full and complete release from liability.

After paying his attorney a one-third contingency fee plus costs and sales tax,

James’s net settlement was $19,927.54.

[¶4.] James’s policy contained both a reimbursement clause and a

subrogation clause. Following the settlement, State Farm demanded

reimbursement from James for the $5,000 payment it made on James’s behalf to

cover medical expenses under the reimbursement clause. State Farm did not

reduce its request to account for the attorney fees and costs James incurred to

obtain his recovery from Rivers. James refused to reimburse State Farm for any

amount; instead, he sued State Farm, seeking a declaratory judgment to determine

his contractual rights under the policy. The parties filed cross-motions for summary

judgment based on stipulated facts.

[¶5.] The circuit court concluded that State Farm could not subrogate

against its own insured. It further held that the reimbursement clause was

ambiguous. As a consequence, the court construed the policy against State Farm,

the drafter, granting summary judgment to James. State Farm appeals, raising one

issue and several sub-issues restated as follows:

1. Whether the language of the reimbursement clause is ambiguous.

2. Whether requiring James to reimburse State Farm implicates the anti-subrogation rule or offends public policy.

3. If State Farm is entitled to reimbursement, whether James is entitled to a portion of his attorney fees.

-2- #28547

Analysis and Decision

[¶6.] “We review a circuit court’s entry of summary judgment under the de

novo standard of review.” Harvieux v. Progressive N. Ins. Co., 2018 S.D. 52, ¶ 9,

915 N.W.2d 697, 700. When conducting this review, “[w]e give no deference to the

circuit court’s decision[.]” Oxton v. Rudland, 2017 S.D. 35, ¶ 12, 897 N.W.2d 356,

360. “When reviewing a circuit court’s grant of summary judgment, this Court only

decides whether genuine issues of material fact exist and whether the law was

correctly applied.” Ass Kickin Ranch, LLC v. N. Star Mut. Ins. Co., 2012 S.D. 73,

¶ 6, 822 N.W.2d 724, 726. Here, there are no disputed facts, so our task is to

determine whether the circuit court correctly applied the law.

[¶7.] Each party filed briefs advising the circuit court of their interpretation

of the policy. James alleged that the reimbursement provision was ambiguous and

should therefore be construed against its drafter, State Farm. In response, State

Farm argued the policy provided it with an unambiguous contractual right to

reimbursement. In addition to the question of ambiguity, the parties also disputed

whether the anti-subrogation rule applied to the reimbursement provision in the

policy.

[¶8.] A brief explanation of these concepts is helpful to understand the

arguments advanced by the parties both before the circuit court and in this appeal.

“[S]ubrogation is a time-honored theory [in which] insurers who pay a loss [for

insureds] are entitled, within the limits of [the] subrogation doctrine, to pursue the

actual wrongdoer.” 16 Steven Plitt et al., Couch on Insurance § 222:4 (3d ed. Supp.

2018); see also Am. Family Mut. Ins. Co. v. Auto-Owners Ins. Co., 2008 S.D. 106, ¶

13, 757 N.W.2d 584, 588. By subrogating a claim, the insurer is allowed to stand in -3- #28547

the shoes of the insured to sue the tortfeasor to recover the payments it made. One

limitation to the doctrine of subrogation, however, is the anti-subrogation rule, a

defense that prohibits insurers from suing their own insureds to recover a loss. See

Plitt, supra § 224:3. Even though the anti-subrogation rule is widely recognized,

courts take varying approaches when applying the rule. 2

[¶9.] Reimbursement, on the other hand, often differs factually from

subrogation because rather than seeking recovery from a third party, it allows “the

insurer to recover policy payments directly from its own insured or beneficiary upon

that party’s recovery of the same loss from a third party . . . .” Id. at § 222:81.

Therefore, although the mechanisms of recovery are different, “the effect of

subrogation and reimbursement are essentially the same.” Id.

[¶10.] James relied upon subrogation principles to argue State Farm was not

entitled to recovery under either the reimbursement or subrogation provisions

based on the anti-subrogation rule. Even though the rule is generally applicable

only to subrogation claims, James contended the language and effect of the

provisions were similar enough to apply the principal of anti-subrogation to the

2. Some courts have held that the rule applies only when co-insureds share insurance coverage under a single policy. See, e.g., Benge v. State Farm Mut. Auto. Ins. Co., 697 N.E.2d 914, 918 (Ill. App. Ct. 1998).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kaiser Trucking, Inc. v. Liberty Mutual
2026 S.D. 5 (South Dakota Supreme Court, 2026)

Cite This Page — Counsel Stack

Bluebook (online)
2019 S.D. 31, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-v-state-farm-sd-2019.