Sevigny, Ins. Comm'r v. British Aviation Ins.

2015 DNH 122
CourtDistrict Court, D. New Hampshire
DecidedJune 16, 2015
Docket15-cv-127-JD
StatusPublished
Cited by2 cases

This text of 2015 DNH 122 (Sevigny, Ins. Comm'r v. British Aviation Ins.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sevigny, Ins. Comm'r v. British Aviation Ins., 2015 DNH 122 (D.N.H. 2015).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Roger A. Sevigny, Insurance Commissioner of the State of New Hampshire, solely in his capacity as Liquidator of The Home Insurance Company

v. Civil No. 15-cv-127-JD Opinion No. 2015 DNH 122 British Aviation Insurance Company Limited and The Marine Insurance Company Limited

O R D E R

Roger A. Sevigny, Insurance Commissioner of the State of

New Hampshire, brought suit in state court, in his capacity as

liquidator of the Home Insurance Company (“Liquidator”), to

collect reinsurance from British Aviation Insurance Company

Limited and The Marine Insurance Company Limited. The

defendants removed the case to this court, and the Liquidator

moves to remand. The defendants object to the motion to remand.

Discussion

The Liquidator contends that the case must be remanded to

state court because the defendants’ reinsurance contracts waive

the defendants’ right to remove through a provision titled,

“Service of Suit Clause (USA).” The Liquidator also asks the

court to order the defendants to pay costs and expenses incurred in seeking remand. The defendants object to the motion to

remand, arguing that the Service of Suit Clause does not waive

their right to remove.

The Liquidator appended a copy of a reinsurance policy to

its complaint as Exhibit A. The Service of Suit Clause

(“Clause”) in the policy provides as follows:

In the event of the failure of Underwriters hereon to pay any amount claimed to be due hereunder, Underwriters hereon, at the request of the Company [sic] will submit to the jurisdiction of any court of competent jurisdiction within the United States and will comply with all requirements necessary to give such court jurisdiction and all matters arising hereunder shall be determined in accordance with the law and practice of such court.

Service of Process in such suit may be made upon

Mendes & Mount, 27, [sic] Williams Street, [sic] New York, N.Y. 10005.

And in any suit instituted against any one of them upon this contract, Underwriters will abide by the final decision of such Court or of any Appellate Court in the event of an appeal.

For purposes of the motion to remand, the defendants do not

dispute that the Clause has been triggered and applies in this

case to the Liquidator’s claims on behalf of The Home Insurance

Company.

A. Removal

“When plaintiffs file a civil action in state court over

which the federal courts would have had original jurisdiction

2 based on diversity of citizenship, the defendants may remove the

action to federal court.” Univ. Truck & Equip. Co., Inc. v.

Southworth-Milton, Inc., 765 F.3d 103, 107-08 (1st Cir. 2014)

(citing 28 U.S.C. § 1441(a)). The plaintiff may then move to

remand the case to state court because of a defect, other than

subject matter jurisdiction, within thirty days of removal. 28

U.S.C. § 1447(c). To oppose a motion to remand, the defendants

bear the burden of showing that removal was proper. Inhabitants

of the Town of Fairfield v. Time Warner Cable Northeast LLC,

2015 WL 1565237, at *1 (D. Me. Apr. 8, 2015); Hanover Ins. Gr.,

Inc. v. Chartis Speciality Ins. Co., 2013 WL 4495659, at *1 (D.

Mass. Aug. 19, 2013); Pacheco v. St. Luke’s Emergency Assocs.,

P.C., 879 F. Supp. 2d 136, 139 (D. Mass. 2012).

There is no dispute that this court has subject matter

jurisdiction based on the parties’ diversity of citizenship and

there is no dispute that the removal was timely. The issue is

whether under the Clause the defendants waived their right to

remove the case. The defendants argue that the Clause is a

permissive forum selection clause, which does not mandate

exclusive jurisdiction in New Hampshire state courts. The

Liquidator contends that the Clause, as a service of suit

provision, constitutes a waiver by the defendants of their right

to remove.

3 B. Service of Suit Clause

The parties agree that federal common law governs

enforcement of forum selection clauses, including the service of

suit clause at issue here.1 Despite that choice, the defendants

state that there may be a conflict among the federal circuit

courts, while the Liquidator supports the choice of federal

common law by showing that both Michigan and New Hampshire

enforce forum selection clauses under ordinary contract

principles. The appropriate inquiry, however, is whether the

applicable state law conflicts with federal common law, because

a conflict would require a determination of whether the

enforceability of the clause was procedural or substantive under

Erie R.R. Co. v. Tompkins, 304 U.S. 64 (1938). See Huffington

v. T.C. Group, LLC, 637 F.3d 18, 23 (1st Cir. 2011); Rafael

Rodriguez Barril, Inc. v. Conbraco Indus., Inc., 619 F.3d 90, 92

(1st Cir. 2010). New Hampshire follows the federal standard

provided in The Bremen v. Zapata Off-Shore Co., 407 U.S. 1, 12

(1972). Hansa Consult of N. Am., LLC v. Hansaconsult

The defendants assert in a footnote that Michigan law should 1

be applied to construe the reinsurance contracts because the original insured, General Motors, is located in Michigan. They acknowledge, however, that no conflict exists between the contract law of Michigan and New Hampshire. The Liquidator cites cases to show that no conflict exists. For that reason, the law of the forum, New Hampshire, would apply. See Reicher v. Berkshire Life Ins. Co. of Am., 360 F.3d 1, 4 (1st Cir. 2004); Aftokinito Props., Inc. v. Millbrook Ventures, LLC, 2010 WL 3168295, at *3 (D.N.H. Aug. 9, 2010).

4 Ingenieurgesellschaft mbH, 163 N.H. 46, 52 (2011). Therefore,

an Erie analysis is unnecessary, and the Bremen standard will

govern the enforceability of the service of suit clause in this

case.

Under the federal standard, the court addresses a forum

selection clause by first determining whether the clause is

mandatory or permissive. Claudio-De Leon v. Sistema Univ. Ana

G. Mendez, 775 F.3d 41, 46 (1st Cir. 2014). A mandatory clause

includes language that “jurisdiction and venue are appropriate

exclusively in the designated forum” while a permissive clause

authorizes jurisdiction and venue in the stated form but does

not preclude litigation elsewhere. Rivera v. Centro Medico de

Turabo, Inc., 575 F.3d 10, 17 (1st Cir. 2009) (internal

quotation marks omitted). If the clause is mandatory and if the

scope of the clause covers the claims at issue, the court then

considers whether the opposing party has provided a strong

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2015 DNH 122, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sevigny-ins-commr-v-british-aviation-ins-nhd-2015.