Progressive Specialty Insurance Company v. Looney

CourtDistrict Court, N.D. Alabama
DecidedSeptember 2, 2025
Docket4:23-cv-01534
StatusUnknown

This text of Progressive Specialty Insurance Company v. Looney (Progressive Specialty Insurance Company v. Looney) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Progressive Specialty Insurance Company v. Looney, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA MIDDLE DIVISION

PROGRESSIVE SPECIALTY INSURANCE COMPANY, Plaintiff, v. Case No. 4:23-cv-1534-CLM

ROBERT LOONEY et al., Defendants.

MEMORANDUM OPINION J&D Transportation caused a disabled vehicle to roll off a trailer and onto the interstate where it struck a vehicle containing Robert Looney and Angel Wright. Looney and Wright sued J&D Transportation for their injuries in state court. Progressive Specialty Insurance Company (“Progressive”) insured J&D Transportation. Progressive filed a declaratory judgment action with this court, asking it to declare that Progressive has no duty to defend or indemnify J&D Transportation in the underlying state case. Progressive moves for summary judgment. (Doc. 29). For the reasons stated within, the court GRANTS Progressive’s motion for summary judgment. BACKGROUND The background facts are either undisputed or read in the light most favorable to Claimants as the nonmoving party. FED. R. CIV. P. 56; see, e.g., Warrior Tombigbee Transp. Co. v. M/V Nan Fung 695 F.2d 1294, 1296 (11th Cir. 1983) (“All reasonable doubts about the facts should be resolved in favor of the non-movant.”). I. The Accident Darius Zanders worked for J&D Transportation. On September 23, 2020, Zanders used one truck (“Unit 1”) and trailer to tow a disabled truck (“Unit 2”) that was parked on the shoulder of the interstate. While pulling the disabled truck onto the trailer, the winch broke and the disabled truck rolled into oncoming interstate traffic, colliding with Claimants’ vehicle.

II. Progressive’s Policy

A. The Policy: At the time of the accident, Progressive insured J&D Transportation. (See Doc. 30-2, p. 11). Under the policy, Progressive had a duty to provide coverage for the following:

Subject to the Limits of Liability, if you pay the premium for liability coverage for the insured auto involved, we will pay damages, other than punitive or exemplary damages, for bodily injury, property damage, and covered pollution cost or expense for which an insured becomes legally responsible because of an accident arising out of ownership, maintenance or use of that insured auto. (Doc. 30-2, p. 43) (emphasis in original) (highlight added). The policy defined “insured autos” as follows:

6. “Insured auto” or “your insured auto” means: a. any auto specifically described on the declarations page; or b. An additional auto for Part I – Liability to Others and/or Part II – Damage to Your Auto on the date you become the owner if: (i) you acquire the auto during the policy period shown on the declarations page; (ii) we insure all autos owned by you that are used in your business (iii) no other insurance policy provides coverage for that auto; and (iv) you tell us within 30 days after you acquire it that you want us to cover it for that coverage. (Id. at pp. 39-40) (emphasis in original). The policy explained that coverage for “insured autos” includes the following: B. When used in Part I – Liability To Others, insured auto also includes: 1. Trailers designed primarily for travel on public roads, while connected to your insured auto that is a power unit;

3. Any temporary substitute auto; (Id. at p. 44) (emphasis in original).

B. Coverage of Involved Vehicles: It is undisputed that the incident in question involved a working truck (Unit 1), a disabled truck (Unit 2), and a trailer. What is disputed is whether Progressive’s insurance policy covered either truck or the trailer at the time of the accident. The court’s task is to determine whether that dispute is genuine under Rule 56.

JURISDICTION Progressive is a citizen of Ohio; Defendants are citizens of Alabama; and the amount in controversy exceeds $75,000, exclusive of interest and costs. (Doc. 1). The court therefore has diversity jurisdiction pursuant to 28 U.S.C. § 1332. STANDARD OF REVIEW 1. Substantive law: Because the court is sitting in diversity, it applies Alabama substantive law. See Palmer & Cay, Inc. v. Marsh & McLennan Companies, Inc., 404 F.3d 1297, 1310 (11th Cir. 2005). 2. Procedural law: In reviewing a motion for summary judgment, the court views the facts and draws all reasonable inferences in the light most favorable to the non-moving party. See Cuesta v. Sch. Bd. of Miami- Dade Cty., 285 F.3d 962, 966 (11th Cir. 2002). Summary judgment is appropriate when there is no genuine dispute of material fact, and the moving party is entitled to judgment as a matter of law. FED. R. CIV. P. 56(a). A genuine dispute of material fact exists when “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). But where the evidence is merely colorable or not significantly probative, no genuine dispute of material fact exists, and summary judgment is appropriate. Id. at 249-50. Further, if the non-movant responds to the motion for summary judgment with just conclusory allegations, the court must enter summary judgment for the movant. Peppers v. Coates, 887 F.2d 1493, 1498 (11th Cir. 1989). DISCUSSION A. Jurisdiction / Ripeness

Before the court can address the merits, it must tackle Defendants’ argument that the court must wait for the state court action to conclude before it decides (a) whether Progressive has a duty to defend and indemnify under the policy and (b) whether an MSC 90 endorsement requires Progressive to indemnify. Defendants point to previous Eleventh Circuit caselaw stating that whether an insurer has a duty to indemnify is not ripe for adjudication until the underlying state action is resolved. (See Doc. 33, p. 9). But the Eleventh Circuit’s recent ruling in Snell v. United Specialty Ins., 102 F. 4th 1208 (11th Cir. 2024), says otherwise. In Snell, an insured landscaper brought a declaratory judgment action against his insurance company, arguing that the insurer had the duty to defend and indemnify him under the controlling insurance policy. In its analysis, the Circuit Court said that the “reading of Alabama law–i.e., as prohibiting a decision on the duty to indemnify until the underlying case goes to judgment–is incorrect.” Id. at 1217. The court said it was unaware of any authority “holding that the duty to indemnify under Alabama law may not be decided before judgment in the underlying litigation.” Id. at 1218. So this court finds that it can presently decide Progressive’s motion.

B. Coverage

There are three ways Defendants can show that Progressive has a duty to indemnify J&D Transportation: (1) one of the trucks was covered by the policy, (2) the trailer was covered by the policy, or (3) the MSC 90 endorsement applies to the accident. The court addresses each below. 1. The trucks (Units 1 and 2) The policy covered four categories of vehicles: (a) an insured auto, (b) additional auto, (c) replacement auto, or (d) a temporary auto. Of these, Defendants argue that Units 1 and 2 were additional autos, covered by the following language: b.

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Related

Liliana Cuesta v. School Board of Miami-Dade
285 F.3d 962 (Eleventh Circuit, 2002)
Palmer & Cay, Inc. v. Marsh & McLennan Companies, Inc.
404 F.3d 1297 (Eleventh Circuit, 2005)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
National Specialty Insurance v. Martin-Vegue
644 F. App'x 900 (Eleventh Circuit, 2016)
James Snell v. United Specialty Insurance Company
102 F.4th 1208 (Eleventh Circuit, 2024)

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Progressive Specialty Insurance Company v. Looney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/progressive-specialty-insurance-company-v-looney-alnd-2025.