Justia U.S. 2nd Circuit Court of Appeals Opinion Summaries

A Vermont statute requires all "health insurers" to file with the State reports containing claims data and other "information relating to health care." Liberty Mutual sought a declaration that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted the Vermont statute and regulation. The district court granted summary judgment in favor of Vermont. The court held that the reporting requirements of the Vermont statute and regulation have a "connection with" ERISA plans and were therefore preempted as applied. The court's holding was supported by the principle that "reporting" is a core ERISA function shielded from potentially inconsistent and burdensome state regulation. Accordingly, the court reversed and remanded with instructions to enter judgment for Liberty Mutual. View "Liberty Mutual Ins. Co. v. Donegan" on Justia Law

The parties disputed ownership of life insurance policies and, according to their contract, submitted the dispute to a rabbinical arbitration panel. The arbitration panel appointed by the parties entered an award mandating the immediate transfer of the insurance policies at issue to Kolel and appellants subsequently appealed. The court concluded that the district court properly denied vacatur based on claims of bias and corruption; properly denied vacatur based on claims of premature decision and failure to consider evidence; and properly denied appellants' motion for reconsideration. Therefore, appellants have not presented any evidence that meets the high burden of proof necessary to vacate an arbitration award, and therefore the district court properly denied their motion for vacatur and granted Kolel's motion for confirmation of that same arbitration award. View "Kolel Beth Yechiel Mechil v. YLL et al." on Justia Law

Pacific issued a fire insurance policy to plaintiff on a home that was destroyed by fire during the policy period. On appeal, Pacific challenged the district court's grant of summary judgment to plaintiff on its claim for a declaratory judgment that an apportionment-of-loss clause in the policy was void as a matter of New York law, and that Pacific was liable to plaintiff for the entire amount of loss coverage shown in the fire insurance policy. Plaintiff cross-appealed from so much of the judgment as ruled that it was not entitled to recover replacement costs in excess of the stated loss coverage amount on the house. The court concluded that plaintiff's contentions were without merit and affirmed to the extent that the district court dismissed plaintiff's claim for extended replacement costs. In regards to Pacific's appeal, the court certified questions to the New York Court of Appeals. View "Quaker Hills, LLC v. Pacific Indemnity Co." on Justia Law

Plaintiff filed suit against Principal after it concluded that he was not eligible for long term disability benefits and denied his claim. The court concluded that Principal failed to properly consider plaintiff's subjective complaints and that Principal's request for objective evidence proving that he suffered from tinnitus was unreasonable. Therefore, the court held that Principal's denial of plaintiff's claim was arbitrary and capricious, and the court reversed the judgment of the district court, remanding for further proceedings. View "Miles v. Principal Life Ins. Co." on Justia Law

Plaintiffs appealed the district court's judgment in favor of Federal, denying plaintiffs indemnification under their insurance policy for the destruction of their barn by fire. The court concluded that the permissive adverse inference instruction with respect to a photograph that plaintiffs had not produced in discovery was appropriate; Federal was not entitled to attorney fees; Federal was not entitled to equitable relief to recover payments made to plaintiffs; and, therefore, the judgment of the district court was affirmed. View "Mali v. Federal Ins. Co," on Justia Law

Charter appealed the district court's holding that it was liable to CGS for its expenses in defending and settling a trademark infringement suit. The court concluded that the relevant insurance policy did not cover the liability alleged in the trademark action and Charter was not liable for the settlement amount; however, there was sufficient legal uncertainty about the coverage issue to oblige Charter to defend the action; and, therefore, the district court's ruling was affirmed insofar as it held that Charter was liable for defense costs, but reversed insofar as it held that Charter was liable for the settlement. Accordingly, the court vacated and remanded for further proceedings. View "CGS Indus., Inc. v. Charter Oak Fire Ins. Co." on Justia Law

Although the court usually may not review voluntary dismissals of claims or denials of motions for summary judgment, this case presented the unusual situation in which the court was asked to review the voluntary dismissal of a claim following a denial of a motion for summary judgment. The court concluded that its review was appropriate in these circumstances because (1) the district court rejected the legal basis for appellants' counterclaim; (2) the district court disposed of all claims with prejudice; and (3) appellants consented to the final judgment solely to obtain immediate appeal of the prior adverse decision, without pursuing piecemeal appellate review. The court also interpreted several "excess" liability insurance policies, which provided insurance protection beyond the protection provided by underlying policies. The court concluded that the plain language of the insurance policies supported the view of the insurer appellees that the excess liability coverage was only triggered when liability payments reached the attachment point. Accordingly, the court affirmed the judgment of the district court. View "Ali v. Fed. Ins. Co." on Justia Law

Plaintiff appealed from the district court's dismissal with prejudice plaintiff's complaint seeking indemnification for property loss caused by fire under an insurance policy. At issue were two provisions in the policy: one requiring the insured to file suit on the policy within two years and the second requiring the insured, seeking replacement costs, to replace the damaged property before bringing suit, and to complete the replacement work as soon as reasonably possible. Because New York law did not clearly resolve the question of what happens to insured property that could not reasonably be replaced within two years, the court certified the question to the New York State Court of Appeals. View "Executive Plaza, LLC v. Peerless Ins. Co." on Justia Law

R.I. Pools appealed from the district court's grant of summary judgment in favor of Scottsdale, which insured R.I. Pools under commercial general liability policies. Scottsdale brought this action seeking declaratory judgment that it had no obligations under the policies with respect to suits brought against R.I. Pools by purchasers of swimming pools for damage the purchasers sustained when cracks developed in their pools. Because the district court erred in ruling that defects in R.I. Pool's work were not within the scope of an "occurrence" and never considered the crucial question whether the defects come within the subcontractor exception to the express exclusion of R.I. Pools's own work, the court vacated the judgment and remanded for further proceedings. Because the duty to defend existed up until the point at which it was legally determined that there was no possibility for coverage under the policies, Scottsdale had not shown entitlement to any reimbursement for defense costs it previously expended. View "Scottsdale Ins. Co. v. R.I. Pools Inc." on Justia Law

Plaintiff sought to recover benefits as the beneficiary of a term life insurance policy upon the death of the insured. The district court entered judgment in favor of the insurance company, holding that it was entitled to rescind the policy because of a material misrepresentation made by the insured in securing the policy, and that plaintiff was therefore not entitled to a benefit. The court affirmed the judgment where plaintiff conceded that the insurance application contained information the insured knew to be untrue when the policy was delivered - that he had Stage IV colon cancer - and where the insurance company would not have issued the policy had the information been correct. View "Smith v. Pruco Life Ins. Co. of N.J." on Justia Law