Wesco Insurance Company v. Strickland

CourtDistrict Court, S.D. Mississippi
DecidedApril 7, 2022
Docket2:20-cv-00160
StatusUnknown

This text of Wesco Insurance Company v. Strickland (Wesco Insurance Company v. Strickland) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wesco Insurance Company v. Strickland, (S.D. Miss. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI EASTERN DIVISION

WESCO INSURANCE COMPANY, et al. PLAINTIFFS

v. CIVIL ACTION NO. 2:20-CV-160-KS-MTP

DARY STRICKLAND, et al. DEFENDANTS

MEMORANDUM OPINION AND ORDER For the reasons provided below, the Court denies Plaintiffs’ Motion for Summary Judgment [88], denies Defendant S & D Mobile Home Movers, LLC’s Motion for Summary Judgment [90], and denies Defendant Dary Strickland’s Motion for Summary Judgment [92]. I. BACKGROUND The Court discussed the background of this case in a previous order. See Wesco Ins. Co. v. Strickland, 2021 WL 2583543, at *1-*2 (S.D. Miss. June 23, 2021). Defendant Dary Strickland filed a lawsuit against Defendant S & D Mobile Home Movers, LLC in state court, alleging that he was injured on an S & D job site. At the time of the accident, S & D had two insurance policies in effect, issued by Plaintiffs. Plaintiffs filed this declaratory-judgment action against Strickland and S & D, asking the Court to declare that they have no duty to defend or indemnify S & D against Strickland’s claims. The parties filed cross-motions for summary judgment. It appears to be undisputed that the policies at issue do not provide coverage for claims asserted by employees for injuries suffered while performing their duties for the employer. Therefore, Plaintiffs argue that Strickland was an employee injured while doing his job, while Defendants argue that he was 1) not working for S & D at the time of the

accident, and 2) at other times hired as an independent contractor. II. STANDARD OF REVIEW Rule 56 provides that “[t]he court shall grant summary judgment if the movant shows 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); see also Sierra Club, Inc. v. Sandy Creek Energy Assocs., L.P., 627 F.3d 134, 138 (5th Cir.

2010). “Where the burden of production at trial ultimately rests on the nonmovant, the movant must merely demonstrate an absence of evidentiary support in the record for the nonmovant’s case.” Cuadra v. Houston Indep. Sch. Dist., 626 F.3d 808, 812 (5th Cir. 2010) (punctuation omitted). The nonmovant “must come forward with specific facts showing that there is a genuine issue for trial.” Id. “An issue is material if its resolution could affect the outcome of the action.” Sierra Club, 627 F.3d at 138. “An issue is ‘genuine’ if the evidence is sufficient for a reasonable jury

to return a verdict for the nonmoving party.” Cuadra, 626 F.3d at 812. The Court is not permitted to make credibility determinations or weigh the evidence. Deville v. Marcantel, 567 F.3d 156, 164 (5th Cir. 2009). When deciding whether a genuine fact issue exists, “the court must view the facts and the inference to be drawn therefrom in the light most favorable to the nonmoving party.” Sierra

2 Club, 627 F.3d at 138. However, “[c]onclusional allegations and denials, speculation, improbable inferences, unsubstantiated assertions, and legalistic argumentation do not adequately substitute for specific facts showing a genuine issue for trial.” Oliver

v. Scott, 276 F.3d 736, 744 (5th Cir. 2002). When, like here, parties file cross-motions for summary judgment, the Court is not required to finally resolve the case by granting summary judgment in favor of one side or the other. Joplin v. Bias, 631 F.2d 1235, 1237 (5th Cir. 1980). Rather, each motion is addressed on its own merits under the applicable standard. Id. II. PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT [88]

Plaintiff Wesco Insurance Company issued Policy #WPP158863200 (the “Wesco Policy”) to Defendant S & D Mobile Home Movers, LLC. Exhibit B to Complaint [1-3], at 6. The Wesco Policy provides commercial auto coverage, id. at 10, and it was effective at the time of the accident which is the subject of Defendant Strickland’s state-court suit against Defendant S & D. Id. at 6. However, the Wesco Policy excludes from coverage all “‘[b]odily injury’ to . . . [a]n ‘employee’ of the ‘insured’ arising out of and in the course of: (1) Employment by the ‘insured’; or (2)

Performing the duties related to the conduct of the ‘insured’s’ business . . . .” Id. at 33. The policy’s definition of an “employee” includes “leased workers,” but does not include “temporary workers.” Id. at 40. The policy provides no further definition of the term “employee.” Plaintiff Amtrust International Underwriters DAC issued Policy

3 #PAL1273981-00 (the “AmTrust Policy”) to Defendant S & D Mobile Home Movers, LLC. Exhibit C to Complaint [1-4], at 2. The AmTrust Policy provides general liability and property coverage, and it was effective at the time of the accident

which is the subject of Defendant Strickland’s state-court suit against Defendant S & D. Id. However, like the Wesco Policy, the AmTrust Policy excludes from coverage all “‘[b]odily injury’ to . . . [a]n ‘employee’ of the insured arising out of and in the course of: (a) Employment by the insured; or (b) Performing duties related to the conduct of the insured’s business . . . .” Id. at 11. The definition of an “employee” includes “a . . . ‘volunteer worker.’” Id. at 41. The AmTrust Policy defines a

“volunteer worker” as “a person who is not your ‘employee,’ and who donates his or her work and acts at the direction of and within the scope of duties determined by you, and is not paid a fee, salary or other compensation by you or anyone else for their work performed for you.” Id. at 25. The AmTrust Policy provides no further definition of the term “employee.” Plaintiffs argue that Strickland was injured while performing his duties as an employee of S & D, and, therefore, the policies exclude such claims from

coverage. In response, Defendants argue that Strickland was not performing any work for S & D at the time of the accident, and that he was not S & D’s “employee” as defined in the policies or otherwise. It appears to be undisputed that the policies would exclude Strickland’s claims against S & D from coverage if he was an employee of S & D injured in the course of that employment or performing duties

4 related to S & D’s business. A. Applicable Law To determine whether an insurance company has a duty to defend its

policyholder against suit, the Court looks “at the facts alleged in the complaint, together with the policy.” Auto. Ins. Co. of Hartford v. Lipscomb, 75 So. 3d 557, 559 (Miss. 2011). “[A]n insurer’s duty to defend is triggered when the allegations of the complaint reasonably bring a claim within the coverage of its policy.” Carl E. Woodward, LLC v. Acceptance Indem. Ins. Co., 749 F.3d 395, 398 (5th Cir. 2014). There is no duty to defend if “the alleged conduct falls outside the policy’s coverage,”

but if the insurer “becomes aware that the true facts, if established, present a claim against the insured which potentially would be covered under the policy, the insurer must provide a defense until it appears that the facts upon which liability is predicated fall outside the policy’s coverage.” Lipscomb, 75 So. 3d at 559.

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Wesco Insurance Company v. Strickland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wesco-insurance-company-v-strickland-mssd-2022.