TIG Insurance v EIFlow Insurance

2015 DNH 186
CourtDistrict Court, D. New Hampshire
DecidedSeptember 29, 2015
Docket14-cv-459-JL
StatusPublished

This text of 2015 DNH 186 (TIG Insurance v EIFlow Insurance) 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 v EIFlow Insurance, 2015 DNH 186 (D.N.H. 2015).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

TIG Insurance Company

v. Civil No. 14-cv-459-JL Opinion No. 2015 DNH 186 EIFlow Insurance Limited

MEMORANDUM ORDER

In this action based on breach of a reinsurance contract,

the parties dispute which statute of limitations applies to the

plaintiff’s claims. The plaintiff, TIG Insurance Company,

brought this suit after unsuccessfully seeking payment from

defendant EIFlow Insurance Limited under a reinsurance contract

that the parties’ respective predecessors-in-interest entered

into in England in 1982. This court has subject-matter

jurisdiction under 28 U.S.C. § 1332(a)(2) (diversity) because TIG

is a citizen of a state, EIFlow is a citizen of a foreign state,

and the amount in controversy exceeds $75,000.

EIFlow has moved for judgment on the pleadings, see Fed. R.

Civ. P. 12(c), or in the alternative for summary judgment, see

Fed. R. Civ. P. 56(d), arguing that New Hampshire’s three-year

statute of limitations for breach of contact claims bars TIG’s

claim for breach of the reinsurance contract. See N.H. Rev.

Stat. Ann. § 508:4. TIG contends that England’s six-year statute

of limitations governs instead. See Limitation Act 1980 § 5. In the alternative, TIG argues, if the New Hampshire statute of

limitation applies, its cause of action accrued within the

limitations period.

After careful consideration of the parties’ written filings

and oral argument, the court denies EIFlow’s motion. The

considerations adopted by the New Hampshire Supreme Court to

guide its choice-of-law analysis with respect to statutes of

limitation favor the application of England’s six-year statute in

this case. And, under that statute of limitations, EIFlow

concedes that TIG’s claim is timely.

I. Applicable legal standard

EIFlow first contends that TIG’s claim is time-barred by New

Hampshire’s statute of limitations, as conclusively established

by the facts alleged in the complaint. A motion for judgment on

the pleadings under Rule 12(c), which permits a party to move for

such judgment after the pleadings are closed, is evaluated under

essentially the same standard as a Rule 12(b)(6) motion for

failure to state a claim. See, e.g., Simmons v. Galvin, 575 F.3d

24, 30 (1st Cir. 2009). For plaintiff’s complaint to survive a

such a motion the plaintiff must allege facts sufficient to

“state a claim to relief” by pleading “factual content that

allows the court to draw the reasonable inference that the

2 defendant is liable for the misconduct alleged.” Ashcroft v.

Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 556 (2007)). A Rule 12(c) motion based on

a statute of limitations succeeds only when “the pleader's

allegations leave no doubt that an asserted claim is

time-barred.” Gorelik v. Costin, 605 F.3d 118, 121 (1st Cir.

2010) (internal quotations omitted).

Submitting evidence outside the confines of the complaint,

EIFlow also seeks a similar outcome on summary judgment. See

Fed. R. Civ. P. 12(c) (“If, on a motion for judgment on the

pleadings, matters outside the pleadings are presented to and not

excluded by the court, the motion shall be treated as one for

summary judgment and disposed of as provided in Rule 56.”); see

also Gulf Coast Bank & Trust Co. v. Reder, 355 F.3d 35, 38 (1st

Cir. 2004). On a motion for summary judgment, the movant must

show “that there is no genuine dispute as to any material fact

and the movant is entitled to judgment as a matter of law.” Fed.

R. Civ. P. 56(a). A dispute is “genuine” if it could reasonably

be resolved in either party's favor at trial, and “material” if

it could sway the outcome under applicable law. See Estrada v.

Rhode Island, 594 F.3d 56, 62 (1st Cir. 2010).

In ruling on a motion for judgment on the pleadings, the

court must accept as true all well-pleaded facts set forth in the

3 complaint and must draw all reasonable inferences in the

plaintiff's favor. See, e.g., Martino v. Forward Air, Inc., 609

F.3d 1, 2 (1st Cir. 2010). Similarly, when analyzing a summary

judgment motion, the court “views all facts and draws all

reasonable inferences in the light most favorable to the

non-moving party.” Estrada, 594 F.3d at 62.

II. Background

The following overview of the facts is drawn from the

complaint and the documents referred to therein and, where noted,

the additional evidence submitted by the parties. As required,

it draws all reasonable inferences in TIG’s favor.

TIG’s predecessor-in-interest, United States Fire Insurance

Company, issued an insurance policy covering a landfill in

California operated by a subsidiary of the insured, Southdown,

Inc. (the “Southdown policy”). U.S. Fire reinsured a portion of

that risk -- 16.2162% of 92.5%, according to TIG -- through a

facultative reinsurance contract with EIFLow’s predecessor-in-

interest, Insurance Corporation of Ireland, PLC (later known as

Icarom). This reinsurance contract -- entered into in London in

19821 -- is the subject of this lawsuit.

1 In support of its objection to EIFlow’s motion, TIG submitted an affidavit from Stephen Manatale, an individual experienced with the London reinsurance market during the

4 Southdown conveyed the landfill to a subsidiary of Browning

Ferris Industries, Inc. in 1987. In 2003, BFI and several

formerly-related entities added U.S. Fire as a defendant in

coverage litigation brought in Texas over losses related to the

landfill. On February 11, 2009, TIG -- having by then succeeded

to U.S. Fire’s interest -- settled with BFI for $13.5 million.

TIG paid out the settlement on February 19, 2009.

TIG allocated $11.9 million of that payout to coverage under

the property section of the Southdown insurance policy and

submitted a claim settlement request for $2.07 million to Icarom

on May 29, 2009. Icarom requested additional information about

the claim and the reinsurance policy. After providing at least

some of this information, TIG followed up with a second request

for an additional $26,531.23 on March 23, 2010.2 On October 20,

2010, Icarom informed TIG that it believed TIG had mis-allocated

relevant period. The precise details of how a reinsurance “slip” was “scratched” in the London market, though interesting, are not directly implicated here. It is enough that EIFlow agrees that the contract was negotiated and effectively signed in London and that the parties would have expected performance there.

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2015 DNH 186, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tig-insurance-v-eiflow-insurance-nhd-2015.