Ramaco Resources, LLC v. Federal Insurance Company, No. 22-1459 (4th Cir. 2023)
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Ramaco Resources suffered a coal silo collapse and submitted a claim for losses to Federal Insurance Company. When Federal denied the claim, Ramaco sued. After a twelve-day trial, a jury awarded Ramaco $7.6 million in contract damages and prejudgment interest. The jury also awarded $25 million under West Virginia’s Hayseeds doctrine, which permits an insured party to claim consequential damages when it prevails after suing to collect on its insurance policy. But post-trial, the district court reduced Ramaco’s contract damages and interest to $1.8 million and entirely rejected the Hayseeds damages as a matter of state law. The district court also conditionally granted a new trial on the Hayseeds award, reasoning that—even if Hayseeds damages were theoretically permissible—the jury’s $25 million award was punitive and thus invalid. Ramaco appealed.
The Fourth Circuit reversed in part and affirmed in part. The court reversed the district court’s reduction of contract damages and prejudgment interest because the insurance policy’s plain language and the trial evidence support the jury’s original $7.6 million award. And the court reversed the district court’s wholesale rejection of Hayseeds damages. But the court affirmed its conditional grant of a new Hayseeds damages trial. The court explained that West Virginia law requires courts to give insurance policies their plain, ordinary meaning whenever possible. Here, the policy’s plain language extended the period of restoration until Ramaco’s operations were restored to the level of generating the net profits that would have existed but for the collapse. To determine that level, a court must consider both throughput and expenses. The district court did not.
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