Jeromy McCrackin v. Tynan Mullen and Safeco Insurance Company of America

CourtMissouri Court of Appeals
DecidedApril 2, 2024
DocketWD86442
StatusPublished

This text of Jeromy McCrackin v. Tynan Mullen and Safeco Insurance Company of America (Jeromy McCrackin v. Tynan Mullen and Safeco Insurance Company of America) 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
Jeromy McCrackin v. Tynan Mullen and Safeco Insurance Company of America, (Mo. Ct. App. 2024).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT JEROMY McCRACKIN, ) ) Respondent, ) v. ) ) ) TYNAN MULLEN, ) WD86442 ) Respondent, ) OPINION FILED: ) April 2, 2024 and ) ) SAFECO INSURANCE COMPANY ) OF AMERICA, ) ) Appellant. )

Appeal from the Circuit Court of Jackson County, Missouri The Honorable Cory L. Atkins, Judge

Before Division Two: Anthony Rex Gabbert, Presiding Judge, and Karen King Mitchell and Janet Sutton, Judges

Safeco Insurance Company of America appeals from the denial of its motion to

intervene in the wrongful death action filed by Jeromy McCrackin and Erica Robinson

(Parents) 1 against Tynan Mullen for the death of their son Riley McCrackin (Victim).

Though the original petition and amendments were filed in Jeromy McCrackin’s 1

name only, Erica Robinson testified at the trial, establishing herself as a person entitled to Safeco sought to intervene for the sole purpose of seeking a stay of the wrongful death

action until a separate declaratory judgment action, filed in federal court, could resolve

whether Safeco had a duty to defend or indemnify Mullen under a homeowner’s policy

provided by Safeco to Mullen’s grandmother. On appeal, Safeco argues that the trial

court erred in denying both its motion to intervene and its motion to stay the wrongful

death action because Safeco had an “undeniable right” to both intervention and a stay

under existing Missouri case law. Finding no error, we affirm.

Background 2

On March 4, 2019, Victim was shot and killed in a parking lot outside of a pool

hall. The probable cause statement from the death investigation indicated that there were

two shooters: Mullen and Logan England. On April 26, 2019, both Mullen and England

were indicted by a grand jury in Jackson County for first-degree murder and armed

criminal action. On September 21, 2021, England pled guilty to a reduced charge of

second-degree murder and armed criminal action in exchange for a sentence of twenty

years’ imprisonment. Mullen’s case was set for a jury trial in November 2023.

On February 3, 2022, Parents filed a wrongful death suit against Mullen, England,

and two others, alleging that the four defendants lured Victim from a pool hall out to a

recover under Missouri’s wrongful death statute, and Jeromy McCrackin requested, under the authority of Rule 55.33(b), that the pleadings be amended to conform with the evidence presented. Mullen’s counsel stated there was “no objection,” and all parties and the court thereafter treated Erica Robinson as a plaintiff in the action. 2 “In reviewing the trial court’s denial of intervention as of right, we consider the facts in the light most favorable to the court’s judgment.” Britt v. Otto, 577 S.W.3d 133, 136 n.3 (Mo. App. W.D. 2019) (quoting Wunderlich v. Wunderlich, 505 S.W.3d 434, 435 n.1 (Mo. App. W.D. 2016)).

2 parking lot, where they ambushed, shot, and killed Victim. Parents accused Mullen of

both participating in a civil conspiracy to shoot and kill Victim and engaging in a battery

(shooting Victim) resulting in Victim’s death.

On October 11, 2022, counsel for Parents sent a letter to Safeco, identifying

Mullen as an insured under a Safeco policy 3 and offering “to settle the wrongful death

claim against [Safeco’s] insured in exchange for [Safeco]’s agreement to pay the total

combined liability coverage limits.” Safeco responded on December 5, 2022, advising

Parents’ counsel that there was no coverage available for the claim presented because the

policy did not provide coverage for (1) “injuries expected or intended by any insured”;

(2) “injuries which are the foreseeable result of an act or omission intended by any

insured”; or (3) “bodily injury which results from violation of criminal law committed by,

or with the knowledge or consent of any insured.” The letter further claimed that “the

policy only provides coverage for an occurrence and it does not appear an occurrence has

been alleged.”

On December 16, 2022, Safeco filed a declaratory judgment action in the United

States District Court for the Western District of Missouri, seeking “a judgment declaring

that, under the Safeco Policy, it has no duty to defend or indemnify Mullen with respect

to the claims against him in the action captioned Jeromy McCrackin v. M[.]H[.], Tynan

Mullen, K[.]C[.], and Logan England, Case No. 2216-CV02028, pending in the Circuit

Court of Jackson County, Missouri, at Independence (the ‘Underlying Litigation’).”

The policy at issue was a homeowner’s policy issued to Mullen’s grandmother, 3

with whom Mullen allegedly lived at the time of the shooting.

3 On December 30, 2022, Parents sought leave to file a first amended petition,

which alleged more specific facts surrounding Victim’s death and each individual’s

involvement, including Mullen. The first amended petition continued to allege that

Mullen participated in a civil conspiracy, but this time, the conspiracy involved scaring

and fighting Victim, rather than shooting and killing him. The first amended petition no

longer alleged that Mullen committed a battery against Victim; instead, it alleged that

Mullen negligently failed to warn Victim of the danger posed by England. The same day,

counsel for Parents sent an email to Safeco, advising Safeco of the first amended petition

and ensuring that Safeco reviewed the allegations of the first amended petition with

respect to the settlement offer.

On January 6, 2023, Safeco sent another letter to Parents’ counsel, advising that

there was no coverage under the allegations of the first amended petition because the

policy did not provide coverage for (1) “injuries which are the foreseeable result of an act

or omission intended by any insured . . . even if the injuries are of a different kind or

degree than expected or intended”; or (2) “bodily injury which results from violation of

criminal law committed by, or with the knowledge or consent of, any insured.” The letter

further indicated that “the policy only provides coverage for an occurrence, and it does

not appear an occurrence has been alleged,” and “there can be no coverage for a claim

that is not cognizable under the law”; the letter noted that “[t]he allegations in the first

amended petition do not support a claim for any type of ‘negligence’ or duty recognized

in Missouri.”

4 On February 24, 2023, Safeco filed a motion for summary judgment in the federal

declaratory judgment action, arguing that there was no coverage under either the original

or first amended petitions:

Regardless of whether Mullen actually shot [Victim], the Amended Petition continues to allege [Victim]’s death was the result of a planned, armed ambush in which Mullen was an active, intentional participant. These allegations “contradict any possibility that [Mullen’s] conduct was mere negligence.” [Cal. Cas. Gen. Ins. Co. of Or. v. Nelson, No. 14-0604-CV- W-BP, 2014 WL 12585786, at *6 (W.D. Mo. Dec. 22, 2014)] (quotations omitted). Thus, for the same reasons that there was no coverage for the claim in McCrackin’s Original Petition, there is no coverage for the claim in his Amended Petition, either.

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Jeromy McCrackin v. Tynan Mullen and Safeco Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeromy-mccrackin-v-tynan-mullen-and-safeco-insurance-company-of-america-moctapp-2024.