TIG Insurance Company v. National Indemnity Company

2023 DNH 029
CourtDistrict Court, D. New Hampshire
DecidedMarch 27, 2023
Docket22-cv-165-SE
StatusPublished
Cited by1 cases

This text of 2023 DNH 029 (TIG Insurance Company v. National Indemnity Company) 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
TIG Insurance Company v. National Indemnity Company, 2023 DNH 029 (D.N.H. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

TIG Insurance Company

v. Case No. 22-cv-165-SE Opinion No. 2023 DNH 029 National Indemnity Company

O R D E R

At issue in this case is the scope of in-state activity

necessary to establish specific jurisdiction over an out-of-

state declaratory-judgment defendant after a successor party to

the subject contract has relocated to the forum state. TIG

Insurance Company (“TIG”) argues that this court has personal

jurisdiction over an out-of-state insurance company, Defendant

National Indemnity Company (“NICO”), for the purpose of a

declaratory judgment action determining the rights and

obligations of the parties to a reinsurance contract originally

issued in 1973. The contract was formed out of state and had not

yet been breached when this suit was filed. Relying on Baskin-

Robbins Franchising LLC v. Alpenrose Dairy, Inc., 825 F.3d 28

(1st Cir. 2016), TIG argues that the court has jurisdiction

because NICO’s communications relating to the claim were

directed to TIG in New Hampshire beginning in 2018. But there is

no evidence that TIG’s asserted claim meaningfully implicates

any of NICO’s contacts with New Hampshire. Rather, it involves only the rights and obligations of the parties under a

previously existing agreement with respect to an

extrajurisdictional settlement. Consequently, the court does not

have jurisdiction and the case is dismissed.

Background

NICO is an insurance company based in Nebraska that issued

liability insurance to the State of Montana in effect from July

1, 1973, until July 1, 1975 (“Montana liability policy”). The

Montana liability policy covered Montana for, among other

things, claims asserted against the state that alleged bodily

injury arising out of the state’s errors or omissions.

To mitigate the potential for loss under the Montana

liability policy, NICO bought reinsurance coverage from several

insurance companies, including TIG’s predecessor, Skandia

Insurance Company Ltd. (“Skandia”). Skandia, a foreign insurance

company based in Stockholm, Sweden with a U.S. Branch in New

York, issued the reinsurance contract through a broker based in

Chicago, Illinois. TIG succeeded Skandia at some point after

Skandia and NICO entered into the reinsurance contract.

Beginning in 2000, workers at the Liberty Mine in Libby,

Montana (“Libby Mine”), brought claims against the State of

Montana to recover for asbestos-related injuries they allegedly

suffered from working in the mine. Montana tendered the claims

2 to NICO in 2002. NICO and Montana litigated and negotiated

NICO’s defense and indemnity obligations over the next 20 years

as claims continued to be made against Montana.

In 2009, Montana and certain Libby Mine claimants entered

into a settlement agreement in the amount of $43 million. In

2011, NICO paid Montana a portion of the settlement amount under

the Montana liability policy. NICO submitted a reinsurance bill

to TIG for a portion of the amount NICO had paid. TIG paid part

of the amount NICO billed in 2017.1

NICO brought a declaratory judgment action against Montana

in February 2012 in Montana state court, seeking a determination

of NICO’s rights, liabilities, and duties, if any, under the

Montana liability policy. Montana brought a counterclaim,

seeking coverage for the miners’ claims. Nat’l Indem. Co. v.

State of Montana, XDDV-20120-140. Litigation related to that

case lasted more than a decade. Montana and NICO eventually

resolved it by entering a settlement agreement on April 19,

2022. The Montana court approved the settlement on May 25, 2022.

While in litigation with Montana, NICO sent status reports

to TIG and its other reinsurers. Prior to 2018, TIG managed and

received communications from NICO regarding the reinsurance

contract, including NICO’s litigation status reports, through

1 The 2009 settlement and TIG’s 2017 payment are not part of this case.

3 TIG’s affiliate in Connecticut. Beginning in 2018, TIG began

managing and receiving communications from NICO regarding the

reinsurance contract through a different affiliate, RiverStone

Claims Management, LLC. RiverStone is located in New Hampshire.

After NICO and Montana entered into the April 2022

settlement agreement, NICO advised TIG that it would bill TIG

under the reinsurance contract for part of the settlement amount

after the Montana court approved the settlement. On May 11,

2022, before the Montana court approved the settlement, and

before NICO billed TIG, TIG filed this declaratory judgment

action. TIG alleges that any amount NICO owes under the

settlement agreement is not covered under the reinsurance

contract. Doc. no. 1, ¶ 29. TIG alleges only one cause of

action, seeking a declaratory judgment “regarding the parties’

rights and obligations under the [reinsurance contract] in

connection with or arising out of the ‘loss’ and ‘loss expense’

actually incurred by NICO under” the Montana liability policy.

Id., ¶ 33. On or around the same day TIG filed this action, two

other reinsurers brought similar suits against NICO in other

jurisdictions. See Global Reinsurance Corp. of Am. v. Nat’l

Indem. Co., 22-cv-3785(JSR) (S.D.N.Y. May 10, 2022); R&Q Ins.

Co. v. Nat’l Indem. Co., C.A. No. 2:22-cv-01807-NIQA (E.D. Pa.

May 10, 2022).

4 On June 6, 2022, after the Montana court approved the

settlement, NICO billed its reinsurers, including TIG, for the

portions of the settlement amount it believed due under their

respective reinsurance agreements. On the same day, NICO filed a

declaratory judgment action in the District of Nebraska against

its reinsurers, including TIG. Nat’l Indem. Co. v. Aioi Nissay

Dowa Ins., et al., 8:22-cv-199 (D. Neb. June 6, 2022).2 The suits

brought by the other reinsurers in the Southern District of New

York and the Eastern District of Pennsylvania have since been

dismissed without prejudice by agreement of the parties in favor

of litigation in the District of Nebraska. Therefore, the cases

currently proceeding in the District of Nebraska include all of

the reinsurers for NICO’s obligations under the Montana

liability policy. TIG’s suit here is the only case regarding

reinsurance obligations for the Montana liability policy that is

not proceeding in the District of Nebraska.

NICO now moves to dismiss, arguing that the court lacks

personal jurisdiction over NICO. Alternatively, NICO argues that

the court should transfer the case to Nebraska. TIG objects,

2 NICO also brought a separate declaratory judgment action against certain other reinsurers in Nebraska on that same day. See Nat’l Indem. Co. v. Liberty Mutual Insur. Co, et al., 22-cv- 200 (D. Neb. Apr. 6, 2022). The reason for, and the existence of, the second Nebraska declaratory judgment action are not material to the court’s order.

5 arguing that this court can exercise personal jurisdiction over

NICO and that transfer to Nebraska would be inappropriate.

I. Personal Jurisdiction

NICO contends that this court lacks personal jurisdiction

over it because NICO has not had sufficient contacts with New

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2023 DNH 029, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tig-insurance-company-v-national-indemnity-company-nhd-2023.