American Family Ins. v. City of Minneapolis, No. 15-3216 (8th Cir. 2016)
Annotate this CaseAmerican Family and Liberty Mutual (Appellants) filed suit against the City after a water-main break in the City flooded the basement condominiums and street-level window wells in the the nearby Sexton building. On appeal, Appellants challenge the district court’s decision on their Equal Protection Clause claim, federal takings claim, and state takings claim. The court concluded that the insurance companies are not similarly situated to the uninsured property owners for purposes of an Equal Protection Clause claim. Even if Appellants could demonstrate that they are similarly situated to the uninsured claimants, the court is satisfied that the reasons proffered by the City, including protecting the welfare of its citizens by minimizing the time claimants were without housing and suffering uncompensated damages, as well as minimizing its own costs and litigation risks, demonstrate that its settlement decisions were rationally related to legitimate, government interests. The court also concluded that because Appellants failed to pursue the available mandamus action in state court, both the state and federal takings claims are not ripe for review by the federal district court. Accordingly, the court affirmed the judgment.
Court Description: Shepherd, Author, with Murphy, Circuit Judge, and Perry, District Judge] Civil case - Insurance. Following a water main break which damaged an apartment building, the City paid claimants, both natural persons and business entities, where insurance did not cover the loss and denied claims made by insurance companies based on losses suffered by their insureds; the two classes were not similarly situated, and the City's decision not to pay the insurers did not violate their Equal Protection rights; even if the insurers were similarly situated, the City's decision was rationally related to a legitimate government interest in protecting the welfare of the City's residents; because the insurers did failed to pursue the available mandamus action in state court, their federal and state takings claims were not ripe for review and were properly dismissed without prejudice. Judge Murphy, concurring.
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