Tieman v. American Risk Services, LLC

CourtDistrict Court, W.D. Missouri
DecidedAugust 22, 2025
Docket4:25-cv-00246
StatusUnknown

This text of Tieman v. American Risk Services, LLC (Tieman v. American Risk Services, LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tieman v. American Risk Services, LLC, (W.D. Mo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION

HOWARD TIEMAN, et al., ) ) Plaintiffs, ) ) vs. ) Case No. 4:25-00246-CV-DGK ) AMERICAN RISK SERVICES, LLC, et al., ) ) Defendants. ) ORDER DENYING MOTION TO REMAND, GRANTING MOTION TO DISMISS This case arises out of allegations that Defendants fraudulently induced Plaintiffs to enter into an agreement to market Plaintiffs’ insurance product by misrepresenting their intent and ability to perform their obligations. Defendants deny the allegations. Plaintiffs filed this case in the Circuit Court of Jackson County, Missouri. Defendants removed to federal court, alleging Plaintiffs fraudulently joined Defendant Arch Insurance Company (“Arch Insurance”) to preclude removal. Now before the Court are Defendant Arch Insurance Company’s 12(b)(6) motion to dismiss all claims against it, ECF No. 10, and Plaintiffs’ Motion to Remand, ECF No. 15. Because the record demonstrates Plaintiffs have no colorable claims against Arch Insurance, the motion to remand is DENIED and the motion to dismiss is GRANTED. All claims against Arch Insurance are DISMISSED WITHOUT PREJUDICE. Standard of Review An action may be removed by the defendant to federal district court if the case falls within the district court’s original jurisdiction. 28 U.S.C. § 1441(a). If the case is not within the court’s original jurisdiction, the court must remand the case to the state court from which it was removed. 28 U.S.C. § 1447(c). To meet the requirements for diversity jurisdiction, the parties must be citizens of different states and the amount in dispute must exceed $75,000. 28 U.S.C. § 1332(a). Complete diversity between the parties is required; the presence of a single plaintiff who is from the same state as a single defendant destroys diversity and extinguishes a federal court’s

jurisdiction to hear the matter. Exxon Mobil Corp. v Allapattah Servs., Inc., 545 U.S. 546, 553 (2005). The burden of establishing federal jurisdiction is on the party seeking removal, In re Bus. Men’s Assurance Co. of Am., 992 F.2d 181, 183 (8th Cir. 1993), and all doubts are resolved in favor of remand, Transit Cas. Co. v. Certain Underwriters at Lloyd’s of London, 119 F.3d 619, 625 (8th Cir. 1997). Fraudulent joinder is an exception to the complete diversity rule. In re Prempro Prods. Liab. Litig., 591 F.3d 613, 620 (8th Cir. 2010). “Fraudulent joinder occurs when a plaintiff files a frivolous or illegitimate claim against a nondiverse defendant solely to prevent removal.” Id. The fraudulent joinder exception prevents the plaintiff from blocking removal by adding nondiverse defendants. Crockett v. R.J. Reynolds Tobacco Co., 436 F.3d 529, 533 (5th Cir. 2006).

For purposes of determining diversity, the court ignores the citizenship of any fraudulently joined defendant. See id. Joinder is fraudulent when there is no reasonable basis in fact or law for the plaintiff’s claims against that defendant. In re Prempro, 591 F.3d at 620. This requires the removing defendant to do more than merely prove that the claims should be dismissed pursuant to a Rule 12(b)(6) motion. Knudson v. Sys. Painters, Inc., 634 F.3d 968, 980 (8th Cir. 2011). If a claim is fraudulently joined, then by definition it cannot survive a Rule 12(b)(6) motion. Id.

2 Factual Background For purposes of resolving the pending motions, the Court adopts the facts alleged in the Complaint as well as those in documents embraced by the Complaint.1 These facts are as follows. Plaintiffs are the developers and/or owners of a novel and lucrative insurance product,

namely a “loan-to-value risk management program for automobile loans.” Compl. ¶¶ 18, 23, ECF No. 1-1. Plaintiffs refer to this product as the LEP/DGP Program.2 To commercialize this product, Plaintiffs sought a partner to assist with sales solicitation, administration, and marketing, as well as an insurance underwriter to underwrite and issue policies. During this time, Plaintiffs began consulting with Glen Ballew (“Ballew”), a recently retired Executive Vice President of Arch Insurance, to bring the LEP/DGP Program to market. Through this process, Plaintiffs were introduced to defendant American Risk Services, LLC (“ARS”), which had a relationship with defendant Arch Insurance through other insurance programs. A meeting was held on August 27, 2019, which involved Plaintiffs, non-party Ballew, and defendants Robert Simpson III (“Simpson”) and Scott W. Satterthwaite (“Satterthwaite”),

Simpson and Satterthwaite, as representatives from ARS, made numerous false representations. Relevant to the pending motions, these representations include that ARS had formed a partnership with Arch Insurance to underwrite other programs; that ARS was able to commit Arch Insurance

1 Plaintiffs’, and to a lesser extent, Defendants’, attempts to bolster the record with new facts by attaching various affidavits to their briefs. These attempts are unavailing. Neither the Eighth Circuit nor the Supreme Court have approved of using documents outside the pleadings to evaluate whether a plaintiff can establish a claim against a diversity-destroying defendant. This Court follows the trend of district courts in this circuit which have declined to consider such materials in determining whether there has been fraudulent joinder. See Dillard v. Silvercote, LLC, No. 4:17-CV-2314 CAS, 2018 WL 2364281, at *4 (E.D. Mo. May 24, 2018) (collecting cases).

2 The acronym is derived from the program’s former name, the Partial Recourse Protection Program, which was later known as Lenders Equity Protection (“LEP”) when it was made available to retail automotive lenders and known as Dealer Guarantee Protection (“DGP”) when made available to automobile dealers.

3 to the LEP/DGP Program as an issuer and underwriter of the policies contemplated by the LEP/DGP Program; and that ARS had secured Arch Insurance’s agreement to go forward with the LEP/DGP Program. Plaintiffs relied on these representations by abandoning efforts to find alternative forms of assistance to bring the LEP/DGP Program to market and entering into an

agreement (“the Agreement”) and a separate letter agreement (“the Letter Agreement”) with ARS on March 30, 2020. The Agreement obligated ARS to solicit automobile dealers or retail automobile lenders to purchase insurance products through the LEP/DGP Program. The Letter Agreement, on the other hand, noted that while an underwriting profit was “no way certain,” “[i]n the event of profits from the underwriting of LEP/DGP, ARS agrees to pay [Plaintiffs] ten percent of that profit.” Compl. Ex. C at 1, ECF No. 1-1. ARS’s representatives made additional representations and admissions after the agreements were signed, essentially re-affirming their commitment to the endeavor. But on August 9, 2021, ARS and Satterthwaite admitted that ARS did not have the distribution to take the Program to dealers or to automobile lenders.

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Related

Crockett v. R.J. Reynolds Tobacco Co.
436 F.3d 529 (Fifth Circuit, 2006)
Knudson v. Systems Painters, Inc.
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992 F.2d 181 (Eighth Circuit, 1993)
Exxon Mobil Corp. v. Allapattah Services, Inc.
545 U.S. 546 (Supreme Court, 2005)
Prempro Products Liability Litigation v. Wyeth
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Bluebook (online)
Tieman v. American Risk Services, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tieman-v-american-risk-services-llc-mowd-2025.