Reliance Insurance v. Enstar Group, Inc.

192 B.R. 579, 1996 U.S. Dist. LEXIS 2024
CourtDistrict Court, M.D. Alabama
DecidedFebruary 12, 1996
DocketCivil Action 94-D-896-N
StatusPublished
Cited by2 cases

This text of 192 B.R. 579 (Reliance Insurance v. Enstar Group, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reliance Insurance v. Enstar Group, Inc., 192 B.R. 579, 1996 U.S. Dist. LEXIS 2024 (M.D. Ala. 1996).

Opinion

MEMORANDUM OPINION AND JUDGMENT

DE MENT, District Judge.

Reliance Insurance Company (“Reliance”) appeals the June 9, 1994, opinion and order entered by the United States Bankruptcy Court for the Middle District of Alabama, 170 B.R. 173. In said opinion and order, the bankruptcy court disallowed the claims of William Gauntt and Aaron Aronov made under a directors and officers’ insurance policy (“D & 0 policy”) and sustained appellee The Enstar Group’s objections to those claims. The bankruptcy court’s order constitutes a final judgment and, thus, is appealable pursuant to 28 U.S.C. § 158(a). 1

The court finds that the bankruptcy court’s findings of fact are not “clearly erroneous,” as they are undisputed. 2 Thus, the court adopts said findings of fact in their entirety. Moreover, the court independently has reviewed the applicable law as applied to the facts and finds that the legal conclusions of the bankruptcy court are particularly well-reasoned. 3 Hence, the court likewise adopts the bankruptcy court’s legal conclusions.

This dispute arises from The Enstar Group’s (the insured) alleged obligation to reimburse Reliance (the insurer) for payments it made to Gauntt and Aronov for legal claims asserted against them in their capacity as officers and directors of The Enstar Group. 4 The D & 0 policy at issue in this case insured The Enstar Group’s directors and officers directly for liability incurred in connection with the performance of their employment duties. Furthermore, this policy provided reimbursement coverage to The Enstar Group for its indemnity obligations to its directors and officers. 5 The policy provided $10 million dollars in coverage subject to a $10 million retention with respect to covered loss for which The Enstar Group was required or permitted to indemnify. The policy also contained a waiver of subrogation clause.

Upon Reliance’s payment of Gauntt and Aronov’s legal costs, Reliance, Gauntt and Aronov entered into a mutual release of liability. The mutual release “preserve[d]” the rights, “if any” of Gauntt and Aronov to seek indemnification from The Enstar Group and of Reliance “to be subrogated to” Gauntt and Aronov’s indemnification rights. The Enstar Group was not a party to this mutual release.

Reliance bases it appeal on the same grounds urged below. That is, the issues for review are:

(1) Whether liquidated, unsecured claims of Gauntt and Aronov against The Enstar *581 Group for indemnification of defense costs and settlement payments incurred in connection with their defense of various shareholder class actions brought against them as outside directors of The Enstar Group should be allowed; and

(2) whether Reliance may recover from The Enstar Group the payments it made for Gauntt and Aronov’s defense costs and settlement amounts in the shareholder class actions either through subrogation or by assignment of Gauntt and Aronov’s indemnification rights. 6

Assignment

The court agrees with the bankruptcy court’s legal analysis and conclusion that the indemnity agreement cut off the indemnity rights of Gauntt and Aronov when their claims were paid through a “valid and collectable insurance policy.” See June 9, 1994 Opinion, at 176 (quoting the indemnity agreement between The Enstar Group and its officers and directors). The court further concurs with the bankruptcy court’s reasoning that the indemnity agreement is the “last word,” so to speak, concerning the legal relationship between The Enstar Group and its officers and directors.

Here, Reliance sought to step in the shoes of Gauntt and Aronov. In that posture, Reliance’s ability to receive reimbursement from The Enstar Group through indemnification was addressed and precluded in the specific terms and conditions of the indemnity agreement between Gauntt and Aronov and The Enstar Group. Reliance could receive no greater rights than those to which Gauntt and Aronov were entitled. 7 Hence, as stated by the bankruptcy court, said legal conclusions of which the court has adopted, “Gauntt and Aronov had no rights to indemnity against The Enstar Group remaining after Reliance paid the settlement amount and the defense costs of the civil litigation. Reliance, therefore, received no rights against The Enstar Group under the purported assignment of indemnification rights from Gauntt and Aronov.” Id. at 177 (footnotes omitted).

Reliance also argues that even if the court affirms the bankruptcy court’s decision that Reliance cannot seek reimbursement from The Enstar Group through subrogation, such a finding does not preclude recovery by assignment. While the court agrees that sub-rogation is not necessarily an insured’s exclusive remedy, the court nonetheless finds that for the reasons stated in the bankruptcy court’s opinion, no right of assignment exists under the facts of this case.

Additionally, the undisputed facts reveal that Reliance chose to take a risk in advancing payment to Gauntt and Aronov instead of pursuing more secure legal alternatives. As the bankruptcy court pointed out, Reliance could have filed a declaratory action, “paid the money under a reservation of its right to determine whether the retention was applicable,” or could have “refused to pay.” Id. at 179. Risk often results in grave consequences, which unfortunately for Reliance is the case here.

Subrogation

Reliance further contends that the bankruptcy court erred in its legal findings that Reliance unconditionally and absolutely waived its subrogation rights in the D & 0 policy and that this waiver prevented Reliance from seeking reimbursement from The Enstar Group. Reliance argues, in part, that the bankruptcy court misconstrued the three cases relied on by Reliance. After carefully reading these cases, the court agrees with the reasoning of the bankruptcy court, which is worthy of restating. Specifically, the bankruptcy court states:

Not one of the three cases supports the contention advanced by Reliance that the *582 waiver of subrogation is not applicable to the payments made by Reliance.
Both Transport and Fashion Tanning 8 are factually inapposite for two reasons.
First the subrogor and the defendant in each case were insured under separate policies. Therefore, there was no contractual relationship between the insurance company and the defendant under the policy pursuant to which the company asserted rights of subrogation. The courts applied general principles of insurance law in declining to impose an automatic bar to sub-rogation.

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Bluebook (online)
192 B.R. 579, 1996 U.S. Dist. LEXIS 2024, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reliance-insurance-v-enstar-group-inc-almd-1996.