Transit Casualty Company, a Body Corporate v. Transamerica Insurance Company, Successor to American Surety Company of New York

387 F.2d 1011, 11 Fed. R. Serv. 2d 55
CourtCourt of Appeals for the Eighth Circuit
DecidedDecember 20, 1967
Docket18747
StatusPublished
Cited by12 cases

This text of 387 F.2d 1011 (Transit Casualty Company, a Body Corporate v. Transamerica Insurance Company, Successor to American Surety Company of New York) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Transit Casualty Company, a Body Corporate v. Transamerica Insurance Company, Successor to American Surety Company of New York, 387 F.2d 1011, 11 Fed. R. Serv. 2d 55 (8th Cir. 1967).

Opinion

HEANEY, Circuit Judge.

This is an appeal in a diversity action brought in the Eastern District of Missouri. A leased building, located in Detroit, Michigan, was damaged in a windstorm. Thereafter, it was extensively damaged in a fire which occurred while the wind damage was being repaired. Transit Casualty Company 1 paid its insured, the lessee, $255,000 for the fire loss and brought action against the Transamerica Insurance Company 2 al *1013 leging that Transamerica had elected to repair the windstorm damage, that the negligence of the subcontractor performing the work caused the fire, and that Transamerica was liable for the damage caused by the subcontractor’s negligence. The case was submitted to the jury and a verdict was returned for the defendant. Transit’s motion for a new trial was denied. It appeals. We remand for a new trial.

I. It was an error to permit the subject of reinsurance to be interjected into the law suit by the defense.

During the cross-examination of an officer of Transit, the defense counsel interjected the fact that Transit had reinsurance treaties with other companies:

“Q. * * * [W]as there any arrangement with any other company made by Transit Casualty to reduce its loss, reinsurance or excess insurance?
“Mr. O’Doherty: I object.
“The Court: Be overruled.
******
“Mr. O’Doherty: * * * [T]he court has indicated here that it’s going to allow defense counsel to inquire into reinsurance treaties—
******
“Mr. O’Doherty: * * * I feel it is prejudicial to this plaintiff’s case to allow Mr. Cleary to interrogate this witness regarding reinsurance treaties, which every insurance company in the United States carries on * * all of its business written, * * * but if it’s the question of whether we have the right to bring the action, that’s not in dispute in this case. It was never raised by any affirmative pleading, * * *
“Mr. Cleary: I would like the record to show that Transit Casualty is one of two plaintiffs here and it is suing in an effort to recover from this jury [$308,000]. Now, I’m interested in ascertaining, and I have a right to know, what loss it actually sustained. Companies, of necessity, or necessarily, or however, it was described, carry excess or reinsurance on a loss, some of them do, some of them don’t. Certainly, the real party in interest here is not Transit Casualty Company if it only sustained, say a $50,000 loss, and I’m entitled to inquire into that in view of the pleadings here.
“The Court: I don’t think it’s a question on an affirmative defense; it’s a question of defense period. You people have the burden of doing the other. I’ll overrule the objection.” (Emphasis added.)

As this colloquy indicates, the defense justified interjecting the issue of reinsurance on the grounds that Transit was not the real party in interest. It has, for all practical purposes, abandoned this argument on appeal conceding, in effect, that the evidence was irrelevant. It now argues that the evidence, though irrelevant, was not prejudicial.

We do not agree. The interjection of the issue of reinsurance was prejudicial error under either Rule 61, Fed. R.Civ.P., or Missouri case law. 3 E. g., Whitman v. Carver, 337 Mo. 1247, 88 S. W.2d 885 (1935); Olian v. Olian, 332 Mo. 689, 59 S.W.2d 673 (1933).

In Olian, the Court stated:

“* * * [T] he fact that the liability of a defendant in a tort action is covered by insurance will, in the minds of the average jury, not only justify a verdict for plaintiff but a very generous assessment of damages as well. * * * with this in mind, plaintiffs’ counsel in actions such as this, and we speak generally, cannot resist the temptation of bringing into the view of the jury an insurance company, a corporate entity that is able to discharge, and whose business it is to discharge, any liability that they may assess for defendant’s wrongdoing. * * * ”

*1014 Id. at 677.

The reasoning of Olian is applicable here. The fact that Transit was reinsured and stood to bear only five percent of this loss is a fact that obviously would impress the jury, and might well lead it to return a defendant’s verdict, as the alternative to such a verdict, in its mind, could well be a windfall to Transit. 4

If counsel, interjecting the issue of insurance, demonstrates that it was done in good faith and was slight, a new trial might not be required. Pitcher v. Schoch, 345 Mo. 1184, 139 S.W.2d 463 (1940); Carter v. Rock Island Bus Lines, 345 Mo. 1170, 139 S.W.2d 458 (1940). Here, however, the interjection was neither in demonstrable good faith nor slight.

The reasons now advanced by the defendant as to why evidence of reinsurance was not prejudicial are: first, the length of jury deliberations do not indicate that it was impassioned against the plaintiff; second, the instructions admonished the jurors to decide the issues fairly and without regard to who the parties were; finally, the error, if any, went only to the issue of damage and as the jury decided against Transit on the issue of liability, it was not prejudicial.

The fact that the jury deliberated at length in this long and difficult case does not, in our view, substantiate the defendant’s position that the jury was not prejudiced by the irrelevant evidence. In our view, it is more likely that the irrelevant, evidence confused the jury and thus prolonged its deliberations. But cf., Sheffield Steel Corp. v. Vance, 236 F.2d 928 (8th Cir. 1956).

Even if the jury instructions had clearly admonished the jury to disregard the issue of reinsurance, 5 the error is, nevertheless, prejudicial. Buehler v. Festus Mercantile Co., 343 Mo. 139, 119 5. W.2d 961 (1938) (en banc); Rytersky v. O’Brine, 335 Mo. 22, 70 S.W.2d 538 (1934); Olian v. Olian, supra; Lindsey v. Rogers, 220 S.W.2d 937 (Mo.App. 1949); Page v. Unttereiner, 106 S.W.2d 528 (Mo.App.1937). But cf., Robinson v. McVay, 44 S.W.2d 238 (Mo.App.1931).

Finally, the argument that the evidence as to reinsurance went only to the issue of damages is neither realistic 6 nor supported by the case law. Whitman v. Carver, supra; Olian v. Olian, supra; Hanna v. Butts, 330 Mo. 876, 51 S.W.2d 9 (1930); Henry v. Tinsley, 240 Mo.App. 163, 218 S.W.2d 771 (1949). Cf., Walton v. United States Steel Co., 362 S.W.2d 617, 627 (Mo.Sup.1962) (dictum); Taylor v. Kansas City Southern Ry.

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387 F.2d 1011, 11 Fed. R. Serv. 2d 55, Counsel Stack Legal Research, https://law.counselstack.com/opinion/transit-casualty-company-a-body-corporate-v-transamerica-insurance-ca8-1967.