New Prime, Inc., a Nebraska Corporation v. McGriff Insurance Services, Inc.

CourtDistrict Court, W.D. Missouri
DecidedFebruary 13, 2024
Docket6:22-cv-03037
StatusUnknown

This text of New Prime, Inc., a Nebraska Corporation v. McGriff Insurance Services, Inc. (New Prime, Inc., a Nebraska Corporation v. McGriff Insurance Services, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
New Prime, Inc., a Nebraska Corporation v. McGriff Insurance Services, Inc., (W.D. Mo. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SOUTHERN DIVISION

NEW PRIME, INC., ) ) Plaintiff, ) ) vs. ) Case No. 6:22-cv-03037-MDH ) McGRIFF INSURANCE SERVICES, INC., ) et al, ) ) Defendants. )

ORDER Before the Court are two summary judgment motions, one from Defendant McGriff (“McGriff”) (successor in interest to “Regions”) and another from Defendant Amwins (“Amwins”) (collectively “Defendants”). Both motions are fully ripe and the Court has considered all briefing. For reasons herein, both pending summary judgment motions are DENIED. BACKGROUND This case involves whether Defendants, Plaintiff’s insurance brokers, were negligent in how they dealt with some of Plaintiff’s insurance coverage, thereby creating a gap in coverage costing Plaintiff millions of dollars. The specific issues at play in the pending Motions for Summary Judgment relate to what duty if any Defendants owed to Plaintiff. Specifically, this Court considers whether: 1) either Defendant had a duty to procure and; 2) either Defendant had an additional duty to advise. Defendants operated as insurance brokers for Plaintiff, a large trucking company with a principal place of business in Springfield, Missouri. Plaintiff’s longtime director of risk retired in or around 2013 and, in his place, Plaintiff hired Ms. Michelle Mertz. Plaintiff’s director of risk was responsible for, inter alia, helping to manage Plaintiff’s insurance needs. Because Ms. Mertz

had relatively little experience in risk management, Plaintiff’s chief financial officer, Mr. Dean Hoedl, asked Mr. Jack Welbourn, a producer with Regions, to serve as a consultant and/or mentor for Ms. Mertz. The parties agree that Mr. Welbourn served as a consultant for Ms. Mertz for a period, but they disagree about the nature and scope of the assistance provided. Amwins operated as a wholesale broker, but Plaintiff alleges that Amwins nonetheless had significant contact with Plaintiff and assumed a significant advising role. Mr. Hoedl offered to pay Mr. Welbourn $50,000 for his consulting services, but Mr. Welbourn declined, conditioned on Mr. Hoedl moving certain policies over to McGriff to manage. (Doc. 114-1 at 6).

The specific insurance policies at issue in this dispute comprise part of a “tower” or “stack” of policies that work to offset Plaintiff’s liability arising from truck collisions. An insurance tower or stack is, simply put, a collection of policies with varying limits and coverage that protect against a certain type of risk. Generally, an effective stack involves policies that interrelate seamlessly, creating neither gaps nor double coverage. Plaintiff alleges that the various insurance products Defendants sold Plaintiff proved ineffective, because they created a coverage gap that caused Plaintiff to incur at least $4,900,000 in defense costs and another undisclosed amount in settlements. These amounts stem from Plaintiff’s defense of a lawsuit brought against Plaintiff

following a December 2015 collision in New Mexico that involved one of Plaintiff’s trucks and caused two deaths. Following settlement in December 2017 of the underlying lawsuit, Plaintiff alleges, Plaintiff was then sued by one of Plaintiff’s insurers seeking reimbursement for the coverage gap. The specific gap at issue, according to Plaintiff, relates to the various ways in which the three policies at issue deal with payment of defense costs. This gap was created, Plaintiff alleges, by Defendants’ failure to procure the specific policies Plaintiff sought and by Defendants’ failure to identify and correct the coverage gap. Plaintiff’s First Amended Complaint alleges two

counts of negligence and one count of breach of fiduciary duty, seeking damages. STANDARD Summary judgment is proper where, viewing the evidence in the light most favorable to the non-moving party, there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a); Reich v. ConAgra, Inc., 987 F.2d 1357, 1359 (8th Cir. 1993). “Where there is no dispute of material fact and reasonable fact finders could not

find in favor of the nonmoving party, summary judgment is appropriate.” Quinn v. St. Louis County, 653 F.3d 745, 750 (8th Cir. 2011). Initially, the moving party bears the burden of demonstrating the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). If the movant meets the initial step, the burden shifts to the nonmoving party to “set forth specific facts showing that there is a genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). To satisfy this burden, the nonmoving party must “do more than simply show there is some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986).

DISCUSSION Under Missouri law, brokers most often serve as agents of the insured. Emerson Elec. Co. v. Marsh & McLennan Companies, 362 S.W.3d 7, 12 (Mo. 2012). When a broker serves as an insured’s agent, the law bestows upon the broker a “duty to the client to act with reasonable care, skill, and diligence” within the scope of the broker’s agency. Id. Most commonly, the scope of a broker’s agency remains limited to procuring sought-after insurance coverage on behalf of the insured. Id. The broker’s duty is therefore typically limited to acting with reasonable care, skill, and diligence in the process of procuring the specific insurance the insured seeks. Id. at 12-13. Should the broker fail to acquire the desired policy, the duty of procurement also requires the

broker to inform the insured accordingly. Id. at 12-13. Beyond this basic duty to procure, however, Missouri law recognizes that certain facts and circumstances may exist that give rise to additional duties, “depending on the relationship of the parties and any agreements between them.” Id. at 20. See, e.g., Zeff Distrib. Co. v. Aetna Cas. & Sur. Co., 389 S.W.2d 789 (Mo. 1965) (recognizing broker’s duty to inform insured of policy’s expiration when broker handled a substantial part of plaintiff’s insurance needs for about nine years); Allstate Indem. Co. v. Dixon, No. 6:14-CV-03489-MDH, 2015 WL 6150586, at *1 (W.D. Mo. Oct. 19, 2015) (recognizing duty to, inter alia, advise insureds on their needs and availability of certain products when policy language states agent “assist[s] customers with their decision- making process”). Further, under Missouri law, the question of what if any duty a defendant owes

a plaintiff in the context of a negligence suit is a matter of law to be determined by the Court. Lopez v. Three Rivers Elec. Co-op., Inc., 26 S.W.3d 151, 155 (Mo. 2000) (“Whether a duty exists is purely a question of law.”). This Court will address whether Defendants have a duty to procure and/or a duty to advise in turn.

I.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Quinn v. St. Louis County
653 F.3d 745 (Eighth Circuit, 2011)
Lopez v. Three Rivers Electric Cooperative, Inc.
26 S.W.3d 151 (Supreme Court of Missouri, 2000)
Manzella v. Gilbert-Magill Co.
965 S.W.2d 221 (Missouri Court of Appeals, 1998)
Zeff Distributing Co. v. Aetna Casualty and Surety Company
389 S.W.2d 789 (Supreme Court of Missouri, 1965)
Emerson Electric Co. v. Marsh & McClennan Companies
362 S.W.3d 7 (Supreme Court of Missouri, 2012)

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New Prime, Inc., a Nebraska Corporation v. McGriff Insurance Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/new-prime-inc-a-nebraska-corporation-v-mcgriff-insurance-services-inc-mowd-2024.