State of Louisiana, Military Department and Department of Public Safety, Office of State Police v. EXPLO Systems, Inc., Crum and Forster Specialty Ins. Co., and Seneca Specialty Ins. Co. (consolidated with) Employers Mutual Casualty Company A/S/O The Village of Dixie Inn, Louisiana v. EXPLO Systems, Inc. and Crum & Forster Specialty Insurance Company

CourtLouisiana Court of Appeal
DecidedMay 18, 2022
Docket54,015-CA 54,016-CA
StatusPublished

This text of State of Louisiana, Military Department and Department of Public Safety, Office of State Police v. EXPLO Systems, Inc., Crum and Forster Specialty Ins. Co., and Seneca Specialty Ins. Co. (consolidated with) Employers Mutual Casualty Company A/S/O The Village of Dixie Inn, Louisiana v. EXPLO Systems, Inc. and Crum & Forster Specialty Insurance Company (State of Louisiana, Military Department and Department of Public Safety, Office of State Police v. EXPLO Systems, Inc., Crum and Forster Specialty Ins. Co., and Seneca Specialty Ins. Co. (consolidated with) Employers Mutual Casualty Company A/S/O The Village of Dixie Inn, Louisiana v. EXPLO Systems, Inc. and Crum & Forster Specialty Insurance Company) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Louisiana, Military Department and Department of Public Safety, Office of State Police v. EXPLO Systems, Inc., Crum and Forster Specialty Ins. Co., and Seneca Specialty Ins. Co. (consolidated with) Employers Mutual Casualty Company A/S/O The Village of Dixie Inn, Louisiana v. EXPLO Systems, Inc. and Crum & Forster Specialty Insurance Company, (La. Ct. App. 2022).

Opinion

Judgment rendered May 18, 2022. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,015-CA No. 54,016-CA (Consolidated Cases)

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

No. 54,015-CA No. 54,016-CA

STATE OF LOUISIANA, EMPLOYERS MILITARY DEPARTMENT MUTUAL AND DEPARTMENT OF CASUALTY PUBLIC SAFETY, OFFICE COMPANY A/S/O OF STATE POLICE THE VILLAGE OF Plaintiffs-Appellees DIXIE INN, LOUISIANA Plaintiffs-Appellees

versus versus

EXPLO SYSTEMS, INC., EXPLO SYSTEMS, CRUM AND FORSTER INC., AND CRUM & SPECIALTY INSURANCE FORSTER SPECIALTY COMPANY AND SENECA INSURANCE SPECIALTY INSURANCE COMPANY COMPANY Defendants-Appellants Defendants-Appellants

Appealed from the Twenty-Sixth Judicial District Court for the Parish of Webster, Louisiana Trial Court Nos. 73438 and 73443

Honorable Allen Parker Self, Jr., Judge

WEEMS, SCHIMPF, HAINES, Counsel for Appellants, SHEMWELL, & MOORE, APLC Crum & Forster By: Carey T. Schimpf Specialty Insurance Kenneth P. Haines Company and Seneca Specialty Insurance Company

THOMPSON, COE, COUSINS & IRONS, LLP Counsel for Appellants, By: Christina Anne Culver Crum & Forster Brian S. Martin Specialty Insurance Kevin Risley Company and Seneca Specialty Insurance Company

PATRICK R. JACKSON, APLC Counsel for 1st Appellees, By: Patrick R. Jackson State of Louisiana, Military Department and Department of Public Safety, and Office of State Police

PETTIETTE, ARMAND, DUNKELMAN, Counsel for 2nd Appellees, WOODLEY, BYRD & CROMWELL, L.L.P. Employers Mutual By: E. Henry Byrd, IV Casualty Company A/S/O Joshua Phillip Monteleone The Village of Dixie Inn Joseph Samuel Woodley

Before MOORE, PITMAN, STONE, HUNTER, and O’CALLAGHAN (Ad Hoc), JJ.

O’CALLAGHAN, J. (Ad Hoc), concurs in part and dissents in part for the reasons assigned.

MOORE, C.J., concurs in part and dissents in part for the reasons assigned by O’Callaghan, J. (Ad Hoc). STONE, J.

The instant litigation arises out of an explosion at Camp Minden,

which the Louisiana Military Department (“LMD”) leased in part to Explo

Systems (“Explo”). The latter was insured by Crum & Forster Specialty Ins.

Co. (“Crum & Forster”) and Seneca Specialty Ins. Co. (“Seneca”), effective

at the time of the explosion and ensuing investigation and emergency

response. Currently before this court is the appeal of defendant-insurers

Crum & Forster and Seneca (collectively, “the insurers”) from the grant of a

partial motion for summary judgment in favor of the plaintiffs, the Louisiana

State Police (“LSP”) and the LMD, in the 26th Judicial District Court,

Honorable Parker Self presiding. Specifically, the trial court judgment

declared the policy exclusion on which the insurers relied in denying

coverage unenforceable. For the following reasons, we reverse.

FACTS

Prior to the issuance of the insurers’ policies in question, insurance

representatives conducted a site visit at Camp Minden. A report based on

that site visit was generated and provided to the underwriters who,

obviously, approved issuance of the respective policies.

Explo was in the business of, among other things, “demilitarizing” the

military’s excess munitions (explosives). The United States Army’s Joint

Munitions Command (“JMC”) held a public bid auction soliciting private

enterprises to bid on a contract to demilitarize munitions containing M6

propellant charges. In competing for the contract, Explo represented to the

JMC that it had unused capacity to (properly) store 70 million pounds of

explosives; however, it was revealed – after the Camp Minden explosion – that capacity did not exist. In March of 2010, the JMC awarded that contract

to Explo. In exchange for demilitarizing the explosives, the United States

Government paid Explo millions of dollars. In connection with this

arrangement, the JMC required Explo to contractually agree to abide by all

applicable laws and regulations and to submit documentation of its

dispositions of the explosives, including the quantity disposed and the

identity of the recipient of the explosives (if any).1 The purpose of this

documentation was to enable the JMC to track the movement of the

explosives and Explo’s inventory levels. Explo quickly reached maximum

lawful storage capacity for the demilitarized M6 propellant, but never

informed the JMC. Instead, Explo submitted fraudulent disposition receipts

to hide the storage capacity problem from the JMC.

Explo’s demilitarization operation was subject to strict regulation and

monitoring. This involved several agencies, including the Defense Contract

Management Agency, the LMD, the Louisiana Department of

Environmental Quality, and the federal Environmental Protection Agency.

The regulations included a maximum limit on the total net amount of

explosives Explo was allowed to have in its respective permitted explosives

storage magazines at Camp Minden. The regulations also specified the type

and location of structures Explo was to use to store the explosives

(hereinafter referred to as “storage magazines”) and the minimum distances

between storage magazines. The Louisiana National Guard made periodic

inspections at Camp Minden meant, in part, to assess Explo’s compliance

1 These documents are referred to as “End User Certificates,” often abbreviated as EUCs. 2 with the applicable laws and regulations, including inventory limits and

compliance with storage protocol.

Explo violated the law and its contract with the JMC by receiving and

holding more M6 propellant at Camp Minden at one time than it could

properly store.2 The JMC paid Explo based on the amount of M6 propellant

Explo demilitarized (i.e., not based on how much was fully disposed). Explo

could demilitarize more explosives than it could properly store or dispose.

Thus, inventory limits—had they been obeyed—would have restricted

Explo’s monetary earnings. As previously mentioned, once the facility

reached its maximum lawful capacity, Explo submitted to the JMC

disposition receipts (called “EUCs”) which, in the aggregate, overstated the

amount of Explo’s outgoing deliveries of demilitarized M6 propellant by

several million pounds. This deception induced the JMC to continue

delivering the explosives despite the excess over the lawful storage capacity.

It also enabled Explo to avoid regulatory enforcement. Additionally, Explo

knew when the inspectors were coming and would hide the excess

explosives off-site in the woods nearby until completion of the inspection.

Also, the doors of the permitted storage magazines were required to bear

placards indicating the contents of the building. Explo would flip the

placards so the blank rear side was showing to create the impression that

there was nothing inside when, in fact, the magazines were at or beyond

maximum capacity. Explo also obstructed the inspections by piling up

objects so as to block the inspector’s access to certain areas in a seemingly

innocuous manner.

2 Several Explo officials pled guilty to conspiracy to defraud the United States and to making false statements to federal officers in relation to the demilitarization contract and operation. 3 As alluded to above, Explo actually sent some demilitarized M6

propellant to various third parties, including Boren Mining Co. In February

of 2012, approximately eight months prior to the Camp Minden explosion,

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State of Louisiana, Military Department and Department of Public Safety, Office of State Police v. EXPLO Systems, Inc., Crum and Forster Specialty Ins. Co., and Seneca Specialty Ins. Co. (consolidated with) Employers Mutual Casualty Company A/S/O The Village of Dixie Inn, Louisiana v. EXPLO Systems, Inc. and Crum & Forster Specialty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-louisiana-military-department-and-department-of-public-safety-lactapp-2022.