Statewide Insurance Fund v. Star Insurance Company

Supreme Court of New Jersey·Decided February 16, 2023·No. A-62-21·Published

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Statewide Insurance Fund v. Star Insurance Company (A-62-21) (086440)

Argued November 7, 2022 -- Decided February 16, 2023

FASCIALE, J., writing for a unanimous Court.

The Court considers which entity has the primary responsibility to pay the settlement of a negligence action brought by the parents of a boy who tragically died from injuries sustained on the Long Branch beach: Statewide Insurance Fund (the Fund), a public entity joint insurance fund (JIF) created under the Joint Insurance Fund Act, or Star Insurance Company (Star), a commercial general liability insurance company. That determination turns on whether the Fund provides “insurance” to its members or whether, instead, the JIF members protect against liability through “self-insurance.” The nature of the JIF protection is essential because the city’s policy with Star contains a clause under which Star’s coverage obligations begin only after coverage available through “other insurance” has been exhausted; the clause, however, does not mention “self-insurance.”

In addition to other protection not relevant here, Long Branch joined the Fund and purchased a commercial general liability policy from Star. As a member of the Fund, Long Branch was entitled to receive $10 million in liability coverage per occurrence. The Fund’s contracting document contains a clause limiting recovery from the Fund to liability in excess over other “insurance or self-insurance” coverage. Under the Star policy, Long Branch had $10 million in liability insurance coverage, excess to a $1 million self-insured retention (SIR). The parties agree that Star’s insurance coverage is excess only over “other insurance.” Payment of the SIR is not an issue on appeal. The question here is which source -- the Fund or Star -- has the primary responsibility to pay the remaining settlement amount.

The trial judge concluded that membership in the Fund did not trigger Star’s “other insurance” clause and that Star had the primary responsibility. The Appellate Division affirmed, and the Court granted certification. 251 N.J. 470 (2022).

HELD: A JIF established under the Joint Insurance Fund Act affords liability protection to public entities through “self-insurance,” not insurance. Here, Star’s “other insurance” clause is not triggered because “self-insurance” protection through JIF membership is not “other insurance.” Star’s coverage is therefore primary. 1 1. The JIF enabling statute provides in part that the governing body of a municipality “may by resolution agree to join together with any other local unit or units to establish a [JIF] for the purpose of insuring against liability . . . through self insurance, the purchase of commercial insurance or reinsurance, or any combination thereof.” N.J.S.A. 40A:10-36 (emphases added). Long Branch joined the Fund to protect against liability through “self-insurance,” and it separately purchased liability insurance, thus complying with N.J.S.A. 40A:10-36. In N.J.S.A. 40A:10- 48, the Legislature directly states that “[a] [JIF] established pursuant to the provisions of this act is not an insurance company or an insurer under the laws of this State, and the authorized activities of the fund do not constitute the transaction of insurance nor doing an insurance business. A fund established pursuant to this act shall not be subject to the provisions of Subtitle 3 of Title 17 of the Revised Statutes.” (emphases added). The JIF Act thus expressly distinguishes JIFs from insurance companies and exempts them from regulatory provisions in Code sections devoted to insurance. New Jersey’s approach is consistent with that of most states which permit governmental risk-pooling, and courts in the jurisdictions with statutes comparable to N.J.S.A. 40A:10-48 have applied those statutes in accordance with their express terms. Applying the clear and plain terms of N.J.S.A. 40A:10-48, the Court holds that JIFs cannot insure members; instead, JIFs enable members to self- insure, spread risk, and reduce insurance costs. As a matter of law, Long Branch’s liability protection as a Fund member is through “self-insurance,” not “insurance.” (pp. 7-13)

2. The Court explains how the general differences in risk allocation between JIFs and commercial general liability carriers reinforce the conclusion that JIF members are self-insured. (pp. 13-16)

3. Because “self-insurance” is not the same as “insurance” under the law, and because membership in the Fund protects against liability claims through self- insurance rather than by insurance through an authorized carrier, Star’s “other insurance” clause is not triggered. Unlike the Fund’s contracting document, which specifies that the Fund’s obligations are excess over “insurance or self-insurance” (emphasis added), Star’s clause states only that insurance coverage available under the Star policy is “excess over . . . any of the other insurance.” Because Star’s clause does not encompass the self-insurance available to members through the Fund, Star’s insurance policy is primary in covering the underlying plaintiffs’ settlement of the negligence action against Long Branch. (p. 17)

AFFIRMED.

CHIEF JUSTICE RABNER; JUSTICES PATTERSON, SOLOMON, PIERRE- LOUIS, and WAINER APTER; and JUDGE SABATINO (temporarily assigned) join in JUSTICE FASCIALE’s opinion. 2 SUPREME COURT OF NEW JERSEY A-62 September Term 2021 086440

Statewide Insurance Fund, a joint insurance fund in the State of New Jersey,

Plaintiff-Respondent,

v.

Star Insurance Company and Meadowbrook, Inc.,

Defendants-Appellants.

On certification from the Superior Court, Appellate Division.

Argued Decided November 7, 2022 February 16, 2023

Thomas E. Schorr argued the cause for appellants (Dilworth Paxson, attorneys; Thomas E. Schorr, on the briefs).

Francis X. Donnelly argued the cause for respondent (Turner, O’Mara, Donnelly & Petrycki, attorneys; Francis X. Donnelly, on the brief).

JUSTICE FASCIALE delivered the opinion of the Court.

This insurance coverage dispute between a public entity joint insurance

fund (JIF) and Star Insurance Company (Star), a commercial general liability 1 insurance company, turns on whether the JIF provides “insurance” to its

members or, instead, the JIF members protect against liability through “self-

insurance.” That distinction is important because Star’s insurance policy

includes a clause under which its coverage obligations begin only after

coverage available through “other insurance” has been exhausted; the clause,

however, does not mention “self-insurance.” Star argues that the JIF provides

insurance and therefore Star’s coverage is excess to the JIF; the JIF disagrees,

contending that because its members are instead “self-insured,” Star’s

coverage is primary.

We hold that a JIF established under N.J.S.A. 40A:10-36 affords liability

protection to public entities through “self-insurance.” Under the plain

language of N.J.S.A. 40A:10-48, a JIF “is not an insurance company or an

insurer under the laws of this State” and its “authorized activities . . . do not

constitute the transaction of insurance nor doing an insurance business.” By

the statute’s plain terms, JIFs cannot provide insurance in exchange for

premiums, as insurance companies typically do; instead, JIF members reduce

insurance costs by pooling financial resources, distributing and retaining risk,

and paying claims through member assessments. Therefore, JIFs protect

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