Richards v. State Farm Fire and Casualty Company

CourtDistrict Court, D. Minnesota
DecidedSeptember 19, 2025
Docket0:24-cv-03192
StatusUnknown

This text of Richards v. State Farm Fire and Casualty Company (Richards v. State Farm Fire and Casualty Company) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richards v. State Farm Fire and Casualty Company, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Kelly Richards, as assignee of insureds, File No. 24-CV-03192 (JMB/SGE) William Dobbs and Karen Arntzen,

Plaintiff,

v. ORDER

State Farm Fire and Casualty Company,

Defendant.

Jenneane Jansen, Jansen & Palmer, LLC, Minneapolis, MN; and Kyle Kosieracki, Tarshish Cody, PLC, Richfield, MN, for Plaintiff Kelly Richards. Scott G. Williams and Lindsey A. Streicher, HAWS-KM, P.A., St. Paul, MN, for Defendant State Farm Fire and Casualty Company.

This matter is before the Court on two motions: (1) Plaintiff Kelly Richards’s objection to the June 4, 2025 ruling of Magistrate Judge Shannon G. Elkins, in which the Magistrate Judge granted Defendant State Farm Fire and Casualty Company’s (State Farm) motion to quash a third-party subpoena issued by Richards’s counsel (Doc. No. 35); and (2) State Farm’s motion for complete summary judgment. (Doc. No. 23.)1 For the reasons discussed below, the Court overrules Richards’s objection to the Magistrate Judge’s ruling granting State Farm’s motion to quash and grants State Farm’s motion for summary judgment.

1 State Farm filed two identical summary judgment motions, one on April 2, 2025 (Doc. No. 13) and one on May 27, 2025 (Doc. No. 23). Because the May 27, 2025 motion superseded the April 2, 2025, it is the only pending motion before the Court. STATEMENT OF UNDISPUTED FACTS AND PROCEDURAL HISTORY A. The Policies

At all times relevant to this lawsuit, William Dobbs and Karen Arntzen were in a romantic relationship and resided together, but they were not married. (Doc. No. 38 ¶ 2– 3.) Dobbs was an insured under a Condominium Unitowners insurance policy (Condo Policy) issued by State Farm. (Doc. No. 25-1 at 2.) According to Arntzen, she believed she was also a named insured on the Condo Policy.2 (Doc. No. 38 ¶ 7.) The Condo Policy provides for a $300,000 liability limit. (Doc. No. 25-1 at 2.)

In an affidavit, Arntzen avers that, upon purchasing a new vehicle in 2017, she reached out to her insurance agent, Ian Davy, to obtain coverage for her vehicle. (Doc. No. 38 ¶ 6.) She avers that Davy suggested that she take out an umbrella policy “to provide further coverage in the event of a large liability loss.” (Id. ¶ 9.) Arntzen agreed, and she took out a personal liability umbrella policy (PLUP) with a $1,000,000 liability limit

through State Farm, which was in effect at all relevant times. (See Doc. No. 25-1 at 3; Doc. No. 38 ¶ 11.) Arntzen believed the PLUP “added umbrella coverage to Mr. Dobbs’[s] and my insurance program [i.e., the Condo Policy].” (Doc. No. 38 ¶ 11.) Dobbs is not a named insured on the PLUP (Doc. No. 25-5 at 1), which only covers: you [Arntzen] and your relatives whose primary residence is your household; . . . any other human being under the age of 21 whose primary residence is your household . . . ; any other person . . . to the extent they are liable for the use of an automobile, recreational motor vehicle or watercraft by a

2 The Condo Policy itself is not in the record. person included [supra]. (Doc. No. 25-5 at 9.) The PLUP defines “relative” as “any person related to you [Arntzen] by blood, adoption, or marriage.” (Id. at 10.) Dobbs does not meet this definition.

The PLUP also provides that the assignment of any rights under the policy are valid “only after we [State Farm] give our written consent” to such assignment. (Id. at 17.) B. The Bicycle Collision and Ensuing Litigation In August 2018, Dobbs and Richards were involved in a bicycle collision on a bike path in Minneapolis. (Doc. No. 25-4 ¶ 1.) Richards was injured. (Id.) Richards brought

a lawsuit against Dobbs in Minnesota state court, alleging that Dobbs’s negligence caused her injuries, which had resulted in significant medical expenses, among other things. See Richards v. Dobbs, No. 27-CV-22-10876, Index #2 (Minn. Dist. Ct. July 22, 2022). Eventually, Richards, Dobbs, and Arntzen (who was not a named party in the lawsuit) entered into a Miller-Shugart-style settlement agreement3 (Agreement) by which

both Dobbs and Arntzen agreed that Richards sustained damages in excess of $1.3 million as a result of Dobbs’s negligence. (Doc. No. 25-4 ¶ 7.) The Agreement provides that State Farm “has acknowledged that it is obligated to indemnify William Dobbs for the claims of Kelly Richards under [the Condo Policy],” but that State Farm “has claimed that it has no obligation to defend or indemnify William Dobbs for the claims of Kelly Richards under

3 Under Miller v. Shugart, 316 N.W.2d 729, 734 (Minn. 1982), if an insurance carrier denies coverage for a liability claim brought by an insured, an insured and plaintiff may agree to the entry of judgment against the insured on the condition that the judgment is collectible only from the insurer. [the PLUP] which provides liability limits of $1,000,000.” (Doc. No. 25-4 ¶ 6; see also Doc. No. 25-3 (denial of coverage letter).) Richards agreed to dismiss the lawsuit upon the

state court’s entry of judgment in Richards’s favor in the amount of $1.3 million, which State Farm was to pay to Richards on Dobbs’s behalf, and that State Farm would pay $300,000 in satisfaction of that judgment. (Doc. No. 25-4 ¶ A.3.) Dobbs and Arntzen purported to assign their respective rights under the PLUP to Richards so that she may pursue a separate coverage action.4 (Id. ¶¶ B.4, C.) Dobbs and Arntzen also agreed to cooperate with Richards “with the investigation and pursuit of any action or proceeding

contemplated by this Agreement.” (Id. ¶ D.4.) C. This Action In August 2024, Richards filed her three-count Complaint. (Doc. No. 1.) In Count I, she alleges that State Farm agreed to provide Dobbs with coverage under the PLUP but breached that policy by failing to provide coverage for Dobbs’s liability to Richards. (Id.

¶¶ 24–29.) In Count II, she alleges that State Farm insurance agent Ian Davy negligently procured insurance for Dobbs and Arntzen.5 (Id. ¶¶ 30–41.) Finally, in Count III, she asserts a claim for reformation of coverage; specifically, she asks that the PLUP should be

4 There is no evidence in the record that State Farm consented to the assignment of rights under the PLUP, and State Farm is not a party to the Agreement. (See Doc. No. 25-4; see also id. ¶ 8 (expressly acknowledging that State Farm “has been placed on notice of the parties’ settlement negotiations, but . . . has declined to participate in any settlement negotiations relating to [the PLUP]”).) 5 Though Count II asserts that Davy engaged in tortious conduct, Richards did not name Davy as a party to the lawsuit. read so as to conform to the Condo Policy to avoid coverage gaps (i.e., to provide coverage for Dobbs’s liability to Richards). (Id. ¶¶ 42–47.)

Discovery commenced in late November 2024. (See Doc. No. 9.) On December 9, 2025, Magistrate Judge Shannon G. Elkins issued a pretrial scheduling order that required the parties to “commence fact discovery procedures in time to be completed on or before May 1, 2025.” (Doc. No. 12 at 2.) As a result, to meet this deadline, any party seeking to serve discovery requests on the other must have done so no later than April 1, 2025. See Fed. R. Civ. P. 33(b)(2) (providing for thirty-day response period), 34(b)(2)(A) (same),

36(a)(3) (same). Richards served no discovery requests on State Farm during the discovery period. For its part, State Farm served discovery requests on Richards. However, Richards did not timely respond to State Farm’s interrogatories and document requests and, when she did, the responses comprised identical and nonspecific objections and advised that “[d]iscovery

is continuing.” (Doc. No.

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