National Casualty Company v. Georgia School Board Association- Risk Management

CourtCourt of Appeals for the Eleventh Circuit
DecidedSeptember 14, 2023
Docket22-13779
StatusUnpublished

This text of National Casualty Company v. Georgia School Board Association- Risk Management (National Casualty Company v. Georgia School Board Association- Risk Management) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Casualty Company v. Georgia School Board Association- Risk Management, (11th Cir. 2023).

Opinion

USCA11 Case: 22-13779 Document: 23-1 Date Filed: 09/14/2023 Page: 1 of 8

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 22-13779 Non-Argument Calendar ____________________

NATIONAL CASUALTY COMPANY, Plaintiff-Counter Defendant-Appellant, versus GEORGIA SCHOOL BOARD ASSOCIATION – RISK MANAGEMENT FUND,

Defendant-Counter Claimant-Appellee.

Appeal from the United States District Court for the Northern District of Georgia D.C. Docket No. 1:16-cv-00691-LMM USCA11 Case: 22-13779 Document: 23-1 Date Filed: 09/14/2023 Page: 2 of 8

2 Opinion of the Court 22-13779

Before LUCK, LAGOA, and BRASHER, Circuit Judges. PER CURIAM: This case is about the apportionment of liability between National Casualty Company and the Georgia School Board Associ- ation – Risk Management Fund, both of which insure Georgia pub- lic school employees. Both parties’ insurance contracts include clauses asserting that when an educator is covered by “other insur- ance,” they’ll only provide “excess” coverage. Applying Georgia law, the district court found these clauses irreconcilable and di- rected the parties to provide coverage on a pro rata basis. We af- firm. FACTUAL BACKGROUND AND PROCEDURAL HISTORY National Casualty is an insurance company that provides policies to the Professional Association of Georgia Educators. The Fund is an agency created by Georgia statute that enables boards of education to share liability risk. Several Georgia educators, who were insured by both Na- tional Casualty and the Fund, were sued. National Casualty and the Fund disagreed about who bore the primary duty to defend and indemnify them. The dispute arose from National Casualty’s and the Fund’s dueling “other insurance” clauses. National Casualty’s clause stated: This policy is specifically excess if the insured has other insurance of any kind whatsoever, whether USCA11 Case: 22-13779 Document: 23-1 Date Filed: 09/14/2023 Page: 3 of 8

22-13779 Opinion of the Court 3

primary or excess, or if the insured is entitled to de- fense or indemnification from any other source what- soever, including by way of example only, such sources as state statutory entitlements or provisions. Other insurance includes, but is not limited to, insur- ance policies, state pools, and programs of self-insur- ance, purchased or established by or on behalf of any EDUCATIONAL UNIT, to insure against CLAIMS arising from activities of the EDUCATIONAL UNIT or its employees, regardless of whether or not the pol- icy or program provides primary, excess, umbrella[,] or contingent coverage. In addition, [Liability Coverage] is specifically excess over coverage provided by any EDUCATIONAL UNIT’S or school board’s errors and omissions or general liability policies, purchased by the insured’s employer or former employers, or self-insurance pro- gram or state pools, whether collectible or not, and it is specifically excess over coverage provided by any policy of insurance which purports to be excess to a policy issued to the insured. The Fund’s clause was shorter. It provided: “If valid and collectible insurance is available to the Member for a loss covered by [the Fund] under any coverage parts within this Coverage Document, the obligations of [the Fund] are excess over the available and col- lectible insurance.” USCA11 Case: 22-13779 Document: 23-1 Date Filed: 09/14/2023 Page: 4 of 8

4 Opinion of the Court 22-13779

National Casualty sued for a declaratory judgment that the Fund had “the primary duty to defend and indemnify” the educa- tors. The Fund counterclaimed. The Fund sought its own declar- atory judgment that National Casualty was at least responsible for covering a pro rata share of the educators’ defense and indemnity costs. The Fund brought two other counterclaims to recover the amounts it had paid to defend and indemnify the educators: a breach of contract and legal contribution claim and an unjust en- richment and equitable contribution claim. National Casualty moved for summary judgment on its claim for declaratory judgment, and the Fund cross-moved for par- tial summary judgment on its claim for declaratory judgment. The district court denied National Casualty’s motion and granted the Fund’s motion. The district court concluded that the parties’ con- flicting “other insurance” clauses couldn’t be reconciled. So the district court applied a Georgia rule that when two insurance poli- cies covering the same risk are irreconcilable, the insurers must share defense and indemnity costs on a pro rata basis. Both parties moved for reconsideration, and the district court certified to the Supreme Court of Georgia whether the irrec- oncilable-clauses rule applied to an entity “entrusted with public funds,” like the Fund. The Supreme Court of Georgia answered that “no law or public policy” prohibited application of the irrec- oncilable-clauses rule simply because the Fund was a creature of statute and not a commercial insurance company. Nat’l Cas. Co. v. Ga. Sch. Bds. Ass’n-Risk Mgmt. Fund, 818 S.E.2d 250, 255–56 (Ga. USCA11 Case: 22-13779 Document: 23-1 Date Filed: 09/14/2023 Page: 5 of 8

22-13779 Opinion of the Court 5

2018). With the answer from the Georgia Supreme Court, the dis- trict court declined to reconsider its partial summary judgment or- der. The parties then filed a joint notice of stipulated facts in which the Fund stipulated to the dismissal of its attorney’s fee counterclaim and both parties withdrew their jury trial demand and requested that the district court enter final judgment. The par- ties said they had “reached a compromise agreement as to how de- fense costs and indemnity obligations” would be shared pro rata to comply with the district court’s partial summary judgment order. They stipulated to the facts necessary to calculate damages and agreed that National Casualty’s pro rata share “to date” for actions related to mutually covered individuals totaled $481,231.84, along with $99,037.51 in prejudgment interest. The parties also reserved their appeal rights. The district court entered final judgment consistent with the parties’ stipulated facts. The judgment explained that—pursuant to the partial summary judgment order and the ensuing stipula- tions—the Fund was awarded the stipulated amounts and future defense and indemnity expenses were to be apportioned equally. National Casualty appeals the partial summary judgment or- der. STANDARD OF REVIEW We review an order granting summary judgment de novo. Amy v. Carnival Corp., 961 F.3d 1303, 1308 (11th Cir. 2020). USCA11 Case: 22-13779 Document: 23-1 Date Filed: 09/14/2023 Page: 6 of 8

6 Opinion of the Court 22-13779

DISCUSSION The irreconcilable-clauses rule has a long pedigree in Geor- gia, starting with State Farm Fire & Casualty Co. v. Holton, 205 S.E.2d 872 (Ga. Ct. App. 1974). There, the Court of Appeals of Georgia held that when “both insurers attempt to limit their liability to ex- cess coverage ‘if there is other insurance,’ then the clauses are ir- reconcilable, cancel each other out, and the liability is to be divided equally.” Id. at 874 (citing S. Home Ins. v. Willoughby, 182 S.E.2d 910, 914 (Ga. Ct. App. 1971)); accord Fund, 818 S.E.2d at 253; Carolina Cas. Ins. v. Underwriters Ins., 569 F.2d 304, 315 (5th Cir. 1978). National Casualty contends that the district court erred in finding that, under Holton, the parties’ “other insurance” clauses canceled each other out and the parties must split defense and in- demnity costs pro rata.

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Related

Southern Home Insurance v. Willoughby
182 S.E.2d 910 (Court of Appeals of Georgia, 1971)
State Farm Fire & Casualty Co. v. Holton
205 S.E.2d 872 (Court of Appeals of Georgia, 1974)
Nat'l Cas. Co. v. Ga. Sch. Bds. Ass'n-Risk Mgmt. Fund
818 S.E.2d 250 (Supreme Court of Georgia, 2018)

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National Casualty Company v. Georgia School Board Association- Risk Management, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-casualty-company-v-georgia-school-board-association-risk-ca11-2023.