Smith v. State Farm Fire & Casualty Co.

656 N.W.2d 432, 2003 Minn. App. LEXIS 140, 2003 WL 282494
CourtCourt of Appeals of Minnesota
DecidedFebruary 11, 2003
DocketC8-02-997
StatusPublished
Cited by10 cases

This text of 656 N.W.2d 432 (Smith v. State Farm Fire & Casualty Co.) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. State Farm Fire & Casualty Co., 656 N.W.2d 432, 2003 Minn. App. LEXIS 140, 2003 WL 282494 (Mich. Ct. App. 2003).

Opinion

OPINION

ROBERT H. SCHUMACHER, Judge.

Appellant State Farm Fire and Casualty Company challenges the district court’s grant of summary judgment to respondent Joan F. Smith, arguing a business-purposes exclusion in Smith’s homeowner’s insurance policy precludes coverage for damage to a structure on her property. We reverse and remand.

FACTS

In June, 1997, Smith purchased residential property in Carver County, Minnesota, that included a home, two pole barns, and various other outbuildings. Smith purchased a homeowner’s policy from State Farm. The policy provided coverage for “the dwelling” (the home) and “structures on the residence premises, separated from the dwelling by clear space,” but excluded from coverage any non-dwelling structure “used in whole or in part for business purposes” or “rented or held for rental to a person not a tenant of the dwelling, unless used solely as a private garage.” The policy was in effect at all times relevant to this dispute.

When Smith purchased the property, she continued the previous owner’s practice of renting one pole barn to a neighbor for car storage. When the neighbor removed the cars in late 1997, a commercial marina rented both barns to store customer boats for the winter. Smith entered into a lease agreement that required the marina to separately insure the boats and its employees and release Smith from liability for any property damage or personal injury associated with the rental.

*435 As part of her 1997 federal tax return, Smith filed a Schedule C-EZ (“Net Profit From Business”) listing “property rental” as her “principal business or profession” and reporting $1,550 “gross receipts from [her] trade or business” and $250 “deductible business expenses.”

For the following three years, Smith rented the barns to commercial marinas for approximately $4,000 each winter. None of the marinas ever received keys to the barns, which remained locked throughout the winter. There is no evidence in the record that Smith notified State Farm, or that State Farm was otherwise aware, that she was renting space in the pole barns.

In February 2001, one pole barn collapsed, apparently due to snow and ice accumulation on its roof. Neither party has alleged that the roof collapse was in any way related to the presence of the boats inside the barn. Smith submitted a claim to State Farm for the loss of the barn. State Farm denied the claim on the grounds that the policy’s business and rental exclusions precluded coverage because Smith was renting the barn for business purposes.

Smith brought suit seeking a declaratory judgment that State Farm was obligated to provide coverage. State Farm moved for summary judgment, arguing coverage was precluded under the policy because Smith was using the barn for business purposes and because Smith was renting the barn for use other than as a private garage.

The district court determined that Smith’s rental conduct was governed by the policy’s rental exclusion, rather than its general business exclusion, “regardless of whether or not [Smith’s] actions could be construed as a ‘business.’ ” Applying the rental exclusion, the court concluded that because the marina was functional!y using the barn as a private garage in which to store vehicles, Smith was entitled to coverage under the rental exclusion’s private garage exception. The court granted summary judgment against State Farm.

ISSUE

Did the district court err by concluding that the rented pole barn was covered under the private garage exception to the rental exclusion in Smith’s homeowner’s policy?

ANALYSIS

We review a grant of summary judgment to determine “whether there are any genuine issues of material fact and whether the district court erred in its application of the law.” Goins v. W. Group, 635 N.W.2d 717, 722 (Minn.2001). Where, as here, there are no relevant facts in dispute, we review de novo the district court’s interpretation of the insurance contract and the contract’s application to the particular facts of the case. Nat’l City Bank v. St. Paul Fire & Marine Ins. Co., 447 N.W.2d 171, 175 (Minn.1989).

“General principles of contract interpretation apply to insurance policies.” Lobeck v. State Farm Mut. Auto. Ins. Co., 582 N.W.2d 246, 249 (Minn.1998). Unambiguous language must be given its plain and ordinary meaning and any ambiguity in a policy must be construed in favor of the insured. Henning Nelson Const. Co. v. Fireman’s Fund Am. Life Ins. Co., 383 N.W.2d 645, 652 (Minn.1986). Policy provisions must be interpreted according to what the insured would have reasonably understood them to mean. Erickson v. Christie, 622 N.W.2d 138, 140 (Minn.App.2001). Provisions must be “given a meaning in accordance with the obvious purpose of the * * * contract as a whole.” Repub *436 lic Nat. Life Ins. Co. v. Lorraine Realty Corp., 279 N.W.2d 349, 354 (Minn.1979) (quotation omitted).

In an action to determine coverage under an insurance policy containing an exclusion clause, the insurer bears the burden of proving the exclusion bars coverage. SCSC Corp. v. Allied Mut. Ins. Co., 536 N.W.2d 305, 313 (Minn.1995).

[Ojnce the insurer shows the application of an exclusion clause, the burden of proof shifts back to the insured because the exception to the exclusion “restores” coverage for which the insured bears the burden of proof.

Id. at 314.

State Farm argues the district court erred by concluding that because the policy’s rental exclusion specifically controlled Smith’s rental actions, the applicability of the “more general” business exclusion need not be considered “regardless of whether [Smith’s] actions could be construed as a ‘business.’ ”

It is true that the policy’s rental and business exclusions are disjunctive, but it is also true that “[a] contract must be interpreted in a way that gives all of its provisions meaning.” Current Tech. Concepts, Inc. v. Irie Enters., Inc., 530 N.W.2d 539, 543 (Minn.1995) (citation omitted); see also Country Club Oil Co. v. Lee, 239 Minn. 148, 151-2, 58 N.W.2d 247, 249 (1953) (stating that “[a]s far as is reasonably possible [a contract] is to be construed so as to harmonize all of its parts”).

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Bluebook (online)
656 N.W.2d 432, 2003 Minn. App. LEXIS 140, 2003 WL 282494, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-state-farm-fire-casualty-co-minnctapp-2003.