GEICO Casualty Co. v. Isaacson, No. 18-2273 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's order granting judgment for GEICO in an action seeking a declaratory judgment that the stacking provisions of other liability coverage in the insurance policy were not applicable to the claims at issue. The court held that the district court did not err in ruling on the declaratory judgment action, because the insurance policy unambiguously did not allow stacking under Missouri law. The court also held that the district court did not abuse its discretion in refusing further discovery, because Missouri law does not permit courts to consider extrinsic evidence in interpreting an unambiguous contract.
Court Description: Gruender, Author, with Colloton and Erickson, Circuit Judges] Civil Case - Diversity. GEICO filed a declaratory judgment action seeking a determination that that the stacking provisions of other liability coverage in the insurance policy are not applicable to the claims presented. The claimants also filed an action in state court raising the same stacking issue. The claimants moved to dismiss the federal action, seeking abstention. The district court granted GEICO summary judgment on the declaratory judgment claim. On appeal, the claimants argue the district court erred in not abstaining or ruling on their motion to dismiss. Because the insurance policy unambiguously did not allow stacking under Missouri law, the district court did not err in ruling on the declaratory judgment action and did not abuse its discretion in refusing further discovery.
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