Essex Insurance Co. v. Janet C. Davidson

Citations: 248 F.3d 716; 2001 U.S. App. LEXIS 7928Docket: 00-2558

Court: Court of Appeals for the Eighth Circuit; May 1, 2001; Federal Appellate Court

Original Court Document: View Document

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

South Metro Human Services, a non-profit providing support for individuals with mental disabilities, had a liability insurance policy with Essex Insurance Company that covered damages from 'wrongful acts,' defined as negligent actions in providing professional services. The policy contained an assault and battery exclusion, which denied coverage for any incidents related to assault or battery. 

In 1996, after a South Metro employee visited the home of Ricky Davidson, who was receiving treatment for schizophrenia, Ricky killed his father, Milton Davidson. Ricky was charged with second-degree murder but found not guilty by reason of mental illness, indicating he could not appreciate the nature or wrongfulness of his actions. Subsequently, Janet Davidson sued South Metro for negligence related to the incident.

In 1999, Essex sought a declaratory judgment asserting that the battery exclusion precluded coverage for any liability arising from the murder. The district court ruled against Essex, stating that because Ricky was found not guilty by reason of mental illness, he lacked the intent necessary to commit a battery, thereby making the exclusion inapplicable. The court affirmed that the harmful contact element of battery was met; however, the lack of intent negated the applicability of the battery exclusion. The case revolves around the interpretation of the insurance contract in light of Minnesota law regarding battery.

In *State Farm Fire Casualty Co. v. Wicka*, the Minnesota Supreme Court addressed whether an intentional act exclusion in an insurance policy applies to injuries caused by individuals with mental illness. The court defined intent as comprising both cognitive and volitional elements, both of which can be affected by mental illness. Consequently, it ruled that acts are deemed unintentional if the insured, due to mental illness, does not understand the nature or wrongfulness of their actions, or cannot control their conduct, irrespective of their understanding.

Essex Insurance Company contended that *Wicka* is not applicable since it addressed an intentional act exclusion, while the case at hand involves a battery exclusion. Essex argued that the battery exclusion applies when there is intent to act but no intent to injure. They cited a trial court finding in the murder case of Ricky Davidson, asserting it demonstrated Davidson intended to harm his father, thus implying he committed a battery. However, this interpretation contradicts *Wicka*, which emphasizes that an isolated statement about intent does not account for the broader context of Davidson's mental illness findings during a bifurcated trial. Therefore, Essex's argument misinterprets the implications of intent as outlined in *Wicka* and overlooks the significance of mental illness in assessing liability under the intentional act exclusion.

Ricky Davidson was found not guilty of a crime due to mental illness, which precluded his ability to form the intent necessary for battery under Minnesota law. The trial court did not address whether Davidson’s insanity affected his intent to commit battery. According to legal precedent, particularly the case of Wicka, a person deemed insane lacks the cognitive ability to form the intent to injure or cause offensive contact. The battery exclusion, while broader than the intentional act exclusion, still requires intent to cause either harmful or offensive contact. The distinction between harmful and offensive contact does not create a scenario where an insane individual could possess the intent for one but not the other. Hence, given Davidson's mental illness, he could not have formed the requisite intent for battery against his father, which means that the battery exclusion in South Metro’s policy does not prevent Essex from covering any damages from the lawsuit filed by Janet Davidson. The district court's decision affirming this conclusion is upheld.