American Modern Home Insurance Co. v. Thomas, No. 19-3054 (8th Cir. 2021)
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American Modern Home filed suit against defendants for insurance fraud after a fire destroyed their home, and the jury found in favor of defendants.
The Eighth Circuit reversed, concluding that the district court did not err by refusing to admit evidence of one of the defendant's three prior convictions for sex offenses because they were highly probative on credibility. Furthermore, the danger of unfair prejudice, undue delay, and confusion did not substantially outweigh the probative value of the evidence. In view of the uncertainty in Missouri law, the court concluded that the district court did not abuse its discretion in its instruction about the meaning of "material" in cases regarding misrepresentations about the fire's cause or a proof of loss. The court also concluded that the district court did not abuse its discretion in giving a supplemental instruction on vexatious refusal to pay in response to a jury question, and the district court did not err in excluding expert testimony on the grounds it was untimely disclosed and cumulative. Accordingly, the court remanded for a new trial.
Court Description: [Benton, Author, with Gruender and Stras, Circuit Judges] Civil case - Insurance. In action alleging insurance fraud after defendants made a claim for losses in an apartment fire, the jury found for defendants and the insurer appeals. Held: the district court erred in refusing to admit evidence of defendant Aaron Thomas's three prior convictions for sex offenses as they were highly probative on credibility, and the danger of unfair prejudice, undue delay and confusion of issues did not substantially outweigh the value of the evidence; in view of the uncertainty in Missouri law, the district court did not abuse its discretion in its instruction concerning the meaning of "material" in the context of a misrepresentation by the insured; the district court did not abuse its discretion in giving a supplemental instruction on vexatious refusal to pay in response to a jury question; the district court did not err in excluding expert testimony on the grounds it was untimely disclosed and cumulative. Reversed and remanded for a new trial
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