Washington Schools Risk Management Pool v. American Re-Insurance Company

District Court, W.D. Washington·Decided August 8, 2023·No. 2:21-cv-00874·Unknown

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 WASHINGTON SCHOOLS RISK CASE NO. 21-CV-00874-LK 11 MANAGEMENT POOL, ORDER GRANTING PLAINTIFF’S 12 Plaintiff, MOTION FOR LEAVE TO AMEND v. AND DENYING AS MOOT 13 DEFENDANT’S MOTION FOR AMERICAN RE-INSURANCE JUDGMENT ON THE PLEADINGS 14 COMPANY and SOMPO INTERNATIONAL REINSURANCE, 15 Defendants. 16 17 This matter comes before the Court on Plaintiff Washington Schools Risk Management 18 Pool’s Motion for Leave to File Second Amended Complaint, Dkt. No. 61, and Defendant 19 American Re-Insurance Company’s Motion for Judgment on the Pleadings, Dkt. No. 66.1 The first 20 motion is granted. The second will be denied as moot. 21

22 1 In September 2006, American Re-Insurance Company rebranded itself as Munich Reinsurance America, Inc. See American Re to Become Munich Re America Starting in Sept., Insurance Journal, 23 https://www.insurancejournal.com/news/national/2006/08/03/71076.htm (last visited June 26, 2023). Defendant accordingly refers to itself as “Munich Reinsurance America” or “MRAm” throughout its briefing. The Court nonetheless refers to Defendant as “American Re-Insurance” in this Order for the sake of continuity and consistency 24 with the case caption and its previous orders. See Dkt. Nos. 49, 55. 1 I. BACKGROUND 2 Washington Schools Risk Management Pool (“Washington Schools”) is an interlocal 3 cooperative whose membership includes several school districts, educational service districts, and 4 other public school interlocal cooperatives. Dkt. No. 27 at 1. It exists “for the purpose of jointly

5 self-insuring risks, jointly purchasing insurance or reinsurance, . . . contracting for joint risk 6 management, [and maintaining] claims and administrative services for the benefit of itself and its 7 member schools.” Id. at 4. In accordance with this purpose, Washington Schools issued three 8 Coverage Agreements to the Puyallup School District (the “District”). Id. at 4–7. The first 9 agreement was effective from September 1, 2003 to August 31, 2004 (the “2003-2004 Coverage 10 Agreement”). Id. at 4. The second agreement was effective from September 1, 2004 to September 11 1, 2005 (the “2004-2005 Coverage Agreement”). Id. And the third agreement was effective from 12 September 1, 2005 to September 1, 2006 (the “2005-2006 Coverage Agreement”). Dkt. No. 62 at 13 8. 14 The Coverage Agreements and Reinsurance Treaties

15 At issue here is the “Errors and Omissions Liability Coverage” under the 2004-2005 and 16 2005-2006 Coverage Agreements. Both policies promise that Washington Schools will indemnify 17 the District for the following damages: 18 Subject to all applicable limits of liability, deductibles, retentions, terms, conditions, and exclusions, the Pool will pay those damages which the District shall 19 become legally obligated to pay as a result of wrongful acts as defined herein, occurring during the term of this Agreement. The Pool will have the right and duty 20 to defend the District against any suit seeking damages as set forth herein. This coverage includes payment of damages which the District shall become legally 21 obligated to pay as a result of wrongful acts arising out of sexual abuse by any District employees or volunteers. 22 Dkt. No. 62 at 9; Dkt. No. 63 at 5; Dkt. No. 64-1 at 43.2 23 24 2 The terms “Sexual Abuse” and “Wrongful Act” are defined in the Coverage Agreements. Dkt. No. 62 at 9; Dkt. No. 1 The Coverage Agreements also limit Washington Schools’ liability in several respects. 2 When, for example, a “wrongful act” spans multiple policy periods, “only the coverage and limits 3 in the last [policy period] in time shall apply and only one wrongful act limit shall be available for 4 each such multi-period . . . wrongful act.” Dkt. No. 64-1 at 44. And claims “based on or arising

5 out of sexual abuse by an employee” are “considered as arising out of one wrongful act and shall 6 be deemed to have been committed at the time of the last of such acts or alleged acts[.]” Id. at 45. 7 This is so regardless of the number of persons sexually abused, the number of locations where the 8 sexual abuse occurred, the number of acts of sexual abuse, and the period of time over which the 9 sexual abuse occurred. Id. (“If a series of related wrongful acts . . . takes place over more than one 10 [policy period], the wrongful acts shall be deemed to have been committed during the last [policy 11 period], only the coverage and limits of that Agreement will apply, and only one wrongful act limit 12 shall be available.”). 13 Washington Schools obtained three reinsurance policies to cover losses exceeding its self- 14 insured limits under the Coverage Agreements with the District. Dkt. No. 27 at 7–8.3 Defendant

15 Sompo International Reinsurance issued the first policy, which covered excess losses between 16 January 1, 2003 and August 31, 2004 (the “2003-2004 Sompo Treaty”). Dkt. No. 27 at 8. American 17 Re-Insurance issued the second and third policies. The second spanned September 1, 2004 to 18 September 1, 2005 (the “2004-2005 American Re-Insurance Treaty”), while the third spanned 19 September 1, 2005 to September 1, 2006 (the “2005-2006 American Re-Insurance Treaty”). Id.; 20 Dkt. No. 62 at 13. The precise terms of the reinsurance policies are not important for today’s 21

63 at 6; Dkt. No. 64-1 at 50. 22 3 “Reinsurance” refers to the relationship that exists when an insurance company (the reinsurer) agrees to indemnify 23 another insurance company (the insurer) against a portion of the losses that the insurer might incur in connection with an underlying policy. Olsen v. United States ex rel. United States Dep’t of Agric., 546 F. Supp. 2d 1122, 1127 (E.D. Wash. 2008). As American Re-Insurance succinctly puts it, “[r]einsurance is essentially insurance for insurers.” Dkt. 24 No. 63 at 3. 1 purposes. What matters is that Sompo agreed to indemnify Washington Schools for losses paid to 2 the District under the 2003-2004 Coverage Agreement, and American Re-Insurance agreed to 3 indemnify Washington Schools for losses paid to the District under the 2004-2005 and 2005-2006 4 Coverage Agreements. See Dkt. No. 27 at 8 (first amended complaint reproducing scope of

5 coverage under Sompo policy); Dkt. No. 64-2 at 4, 27 (scope of coverage under American Re- 6 Insurance policies). 7 The Underlying Sexual Abuse Lawsuits 8 Between 2005 and 2020, three students sued the District and former teacher Timothy 9 Paulsen in state court for alleged sexual abuse and other misconduct stretching back to the early 10 1990s. Dkt. No. 27 at 2–4. These three lawsuits—referred to by the parties as the “R.G. Suit,” 11 “R.B. Suit,” and “J.B. et al. Suit”—resulted in settlements and defense costs totaling approximately 12 $10 million. Id. at 4; Dkt. No. 80 at 18. Although Washington Schools footed the bill pursuant to 13 its Coverage Agreements with the District, the expenses associated with the lawsuits exceeded the 14 self-insured limits in those agreements. Dkt. No. 27 at 7, 9. It accordingly turned to Sompo and

15 American Re-Insurance for reimbursement. 16 Washington Schools Pursues Sompo 17 Washington Schools “provided relevant documents regarding its payment of defense, 18 judgment, and settlement of claims . . . to both Sompo and American Re[-Insurance],” but initially 19 asked only Sompo to reimburse its excess losses pursuant to the 2003-2004 Sompo Treaty. Id. at 20 9; Dkt. No. 62 at 2 (detailing submission of claim to Sompo); Dkt. No. 79 at 4 (“[T]he only 21 allegations of breach were against Sompo[] because at that time [Washington Schools] had not 22 requested reimbursement from American Re[-Insurance].”). Sompo denied coverage. Dkt. No. 27 23 at 9.

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