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Burnett v. Cincinnati Insurance

Citations: 690 N.E.2d 747; 1998 Ind. App. LEXIS 16; 1998 WL 21983Docket: 87A04-9708-CV-343

Court: Indiana Court of Appeals; January 23, 1998; Indiana; State Appellate Court

Narrative Opinion Summary

In a dispute over insurance coverage following mine subsidence damage, the Burnetts sought a declaratory judgment against Cincinnati Insurance Company. The Burnetts' property, insured under a homeowner's policy with an 'Indiana Mine Subsidence Coverage Endorsement,' suffered damage attributed to mine subsidence. The endorsement provided coverage up to $75,000 per structure but excluded earth movement not related to inactive coal mine collapses. The Burnetts claimed additional coverage for non-structural losses, arguing the policy language was ambiguous. However, the trial court granted summary judgment to Cincinnati Insurance, affirming the $75,000 limit and ruling no further compensation was due. On appeal, the Court of Appeals of Indiana upheld the trial court's decision, highlighting the clarity of the policy's terms and the appropriateness of summary judgment. The court also noted the Burnetts' waiver of their non-structural damage claim due to insufficient argumentation. Ultimately, the appellate court confirmed the policy's exclusion of earth movement losses and the insurer's liability limits, ensuring the judgment favored Cincinnati Insurance.

Legal Issues Addressed

Ambiguity in Insurance Contracts

Application: The court found no ambiguity in the policy language, which was clear and unambiguous, and therefore, did not warrant a broader interpretation favoring the insured.

Reasoning: Clear and unambiguous policy language should be interpreted favorably to the insured, aiming to uphold the policy's indemnity purpose.

Interpretation of Insurance Policy Exclusions

Application: The court affirmed the interpretation of the insurance policy, which excluded earth movement from coverage but provided specific coverage for mine subsidence.

Reasoning: The policy explicitly excludes losses from earth movement, including 'earth sinking,' and defines mine subsidence as the collapse of inactive underground coal mines.

Limits of Mine Subsidence Coverage

Application: The insurance policy's mine subsidence endorsement was upheld to limit coverage to $75,000 per structure, consistent with the policy terms.

Reasoning: Cincinnati Insurance determined their maximum compensation under the policy's mine subsidence endorsement was $75,000.

Summary Judgment Standards

Application: Summary judgment was deemed appropriate as no material facts were disputed and the law supported the insurer's position.

Reasoning: The court highlighted that summary judgment is appropriate when no material facts are disputed and the law supports the moving party's position.

Waiver of Arguments on Appeal

Application: The Burnetts waived their argument for additional coverage by failing to provide coherent legal arguments and citations in their appeal.

Reasoning: Cincinnati contended that the Burnetts waived this argument due to their lack of a coherent presentation on appeal, a point the court upheld.