Reisbeck v. Farmers Insurance ExchangeAnnotate this Case
The Supreme Court reversed the order of the district court granting summary judgment in favor of Farmers Insurance Exchange on Plaintiff's claim for underinsured motorist (UIM) benefits, holding that Plaintiff's UIM claim was not barred by either the doctrine of issue preclusion or claim preclusion.
Plaintiff sued Darrell King alleging damages resulting from injuries he sustained when King rear-ended him. King was insured by Progressive Northwestern Insurance Company, and Plaintiff was insured by Farmers. When Farmers refused to pay Plaintiff anything under his UIM coverage Plaintiff filed a lawsuit against Farmers to recover his UIM benefits. Plaintiff's lawsuit against King subsequently went to trial, and the jury awarded Plaintiff $10,000 in damages. Before the district court entered judgment, the parties settled for $50,000 - the policy limits of King's liability coverage with Progressive. Thereafter, Farmers moved for summary judgment on Plaintiff's UIM coverage claim, arguing that because Plaintiff had settled with King, his UIM claim was barred by issue preclusion and claim preclusion. The district court granted summary judgment for Farmers. The Supreme Court reversed, holding that a contract claim for UIM benefits is wholly distinct and separate from the underlying third-party tort claim, and therefore, Plaintiff's complaint was barred by neither issue preclusion nor claim preclusion.