Allstate Indemnity Co. v. Dixon, No. 18-1948 (8th Cir. 2019)
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Allstate filed suit seeking a declaratory judgment that the insureds violated the intentional acts exclusion of their insurance policy and that Allstate was entitled to recover its payment to the mortagees. Allstate concluded that the insureds' property was set on fire by or at the direction of one of the insureds. The district court denied the insureds' motion for summary judgment, and Allstate prevailed at trial.
The Eighth Circuit affirmed, holding that the district court did not make a clear and prejudicial error affecting the outcome of the proceeding by admitting the expert opinions; the district court did not err in denying the insureds' motion for judgment as a matter of law, because the combination of Allstates' expert testimony regarding the possible causes of the fire, the rapid nature of the blaze, evidence of the insureds' financial incentives, and potential negative credibility determinations by the jury against the insureds suffices to meet the burden of submissibility; the denial of the insureds' motion for a new trial was not a miscarriage of justice in light of the evidence; the district court was entitled to order restitution of the amount paid the mortgagees as a means of effectuating the verdict in favor of Allstate in a declaratory judgment action; and judgment was properly entered against the co-insured, even where the verdict director focused on the other insured.
Court Description: Erickson, Author, with Colloton and Gruender, Circuit Judges] Civil case - Insurance. The district court did not err in admitting Allstate's experts' testimony regarding the cause of the fire in issue; the evidence in the case, together with the reasonable inference to be drawn therefrom, was sufficient to meet Allstate's burden of submissibility, and the district court did not err in denying defendants' motion for judgment as a matter of law; denial of defendants' motion for new trial was not a miscarriage of justice in light of the evidence; Allstate was entitled to recover the money it paid defendant's mortgagees.
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