Northwest Pump & Equipment Co. v. American States Insurance

925 P.2d 1241, 144 Or. App. 222, 1996 Ore. App. LEXIS 1594
Court of Appeals of Oregon·Decided October 23, 1996·No. 941007023; CA A89666·Published·Cited by 31 cases

Opinions

[224] LANDAU, J.

Defendant petitions for reconsideration of our opinion, 141 Or App 210, 917 P2d 1025 (1996), in which we (1) held that defendant had wrongfully refused to defend plaintiff, its insured, against a claim brought by a third party, (2) held that, as a result, defendant is liable for the amount that plaintiff agreed to pay the third party in settlement of the claim brought by the third party, to the extent that the settlement was reasonable, and (3) remanded for a determination of the reasonableness of the settlement that plaintiff actually negotiated with the third party. Defendant does not challenge the first holding but does challenge the second and third. According to defendant, an insurer that wrongfully refuses to defend is liable for a reasonable settlement between an insured and a third party only if the underlying event that gave rise to the third-party action was covered under the policy of insurance. Defendant argues that, if the underlying event in this case fell within its pollution exclusion clause, then it cannot be held liable even if the settlement was otherwise reasonable, because insurers cannot be penalized for failing to defend by being required, in effect, to provide coverage they never agreed to provide. We agree and modify our opinion, adhering to it as modified.

No Oregon decision defines precisely the consequences of an insurer’s wrongful refusal to defend. Courts in other jurisdictions have taken various approaches. A substantial number hold that an insurer that has wrongfully refused to defend is estopped from denying coverage. See, e.g., Joslyn Mfg. Co. v. Liberty Mut. Ins. Co., 23 F3d 1212, 1214 (7th Cir 1994) (“[b]y violating its duty to defend, under Illinois law the insurer is estopped to deny policy coverage in a subsequent lawsuit”); Qualman v. Bruckmoser, 163 Wis 2d 361, 368, 471 NW2d 282, 285 (1991) (“[i]f the insurance company breaches its duty to defend its insured in the underlying action against the insured, the company cannot later challenge any coverage issues”). That rule is generally supported by the rationale that, because the insurer has breached the insurance policy, it is no longer entitled to claim any of its protective provisions. See, e.g., Clemmons v. Travelers Ins. Co., 88 Ill 2d 469, 479, 430 NE2d 1104, 1109 (1981) (the [225] “roots [of the rule] lie in the theory that because the insurer breached one of its duties under the contract of insurance * * *, the insurer cannot later turn around and enforce another clause of the contract, to its complete protection”).

Other courts reject the extension of coverage by estoppel and hold that an insurer that wrongfully fails to defend is responsible for settlement costs only to the extent that the underlying claim is covered. See, e.g., Polaroid Corp. v. Travelers Indem. Co., 414 Mass 747, 762-63, 610 NE2d 912, 921 (1993) (“[i]f an underlying claim * * * is not within the coverage of an insurance policy, an insurer’s improper failure to defend that claim would not ordinarily be a cause of any payment that the insured made in settlement of that claim”); Hirst v. St. Paul Fire & Marine Ins. Co., 106 Idaho 792, 799, 683 P2d 440, 447 (1984) (“where an insurance company has wrongfully refused to defend, it may nevertheless in a subsequent action on the policy attempt to show that the liability is not covered by the policy”) (quoting Afean v. Mutual Fire, Marine and Inland Ins. Co., 595 P2d 638, 647 (Alaska 1979)); Keller Industries v. Emp. Mut. Liab. Ins. Co., 429 So 2d 779, 780 (Fla Dist Ct App 1983) (“an unjustified failure to defend does not require the insurer to pay a settlement where no coverage exists”); Alabama Farm Bur. Mut. Cas. Ins. Co. v. Moore, 349 So 2d 1113, 1116 (Ala 1977) (“[W]e reject the proposition that an insurer’s liability to pay for damages may stem from a breach of its duty to defend. The two duties are to that extent independent.”); see also R. Long, 1A The Law of Liability Insurance § 5A.18 at 5A-107 (1966 & Cumm Supp 1994) (“[T]he insured must prove that the amount paid in settlement was reasonable in order to be able to recover those amounts, and that the claim was within the policy coverage.”). The principal underpinning of that rule is the idea that policy holders are entitled to receive the benefit of their bargains and no more. As one commentator has explained:

“The insurer’s breach [of the duty to defend] should not * * * be used as a method of obtaining coverage for the insured that the insured did not purchase. When a contract is breached, the injured party is entitled to receive what would have been obtained if there had been no breach; the injured party is not entitled to receive more.”

[226] Allan D. Windt, 1 Insurance Claims and Disputes § 4.37 at 268 (3d ed 1995).

Oregon is among the jurisdictions that have rejected the rule that insurers that wrongfully fail to defend are estopped from contesting coverage as to settlement costs. In Timberline Equip, v. St. Paul Fire and Mar. Ins., 281 Or 639, 576 P2d 1244 (1978), the insurer had breached its duty to defend, the insured had settled claims asserted by a third party, and the insured sued the insurer for recovery of all settlement costs. The insured argued that, by failing properly to defend, the insurer had waived any right to contest coverage and was, consequently, liable for the entire settlement. The Supreme Court disagreed:

“That argument is incorrect. When a contract is breached the injured party is entitled to receive what he would have if there had been no breach; he is not entitled to receive more.”

Id. at 646. Timberline, however, did not address the question of what other consequences, if any, attend an insurer’s wrongful failure to defend. More precisely, Timberline did not address whether Oregon follows the decisions of other states holding that an insurer that wrongfully fails to defend generally will not be liable for settlement costs unless the underlying claim is covered. To answer that question we work from more fundamental principles of Oregon contract and insurance law. Three such principles are pertinent to the disposition of this matter.

First, the duty to defend is a contractual duty, and, under general principles of contract law, the breach of that duty gives rise to a claim for damages. Georgetown Realty v. The Home Ins. Co., 102 Or App 611, 615, 796 P2d 651 (1990), rev’d on other grounds 313 Or 97, 831 P2d 7 (1992). The measure of those damages is generally stated in terms of the “benefit of the bargain,” Corder v. A&J Lumber Co, Inc., 223 Or 443, 449, 354 P2d 807 (1960), subject to a limitation of foreseeability. Foreseeability, it should be emphasized, is determined from the time of execution of the agreement, not from the time of the breach. Cont. Plants v. Measured Mkt., 274 Or 621, 625-26, 547 P2d 1368 (1976).

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Northwest Pump & Equipment Co. v. American States Insurance, 925 P.2d 1241, 144 Or. App. 222, 1996 Ore. App. LEXIS 1594 (Or. Ct. App. 1996).

925 P.2d 1241 (Northwest Pump & Equipment Co. v. American States Insurance) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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