Aetna Casualty & Surety Co. v. Wannamoisett Country Club, Inc.
Docket: No. 97-45-Appeal
Court: Supreme Court of Rhode Island; January 22, 1998; Rhode Island; State Supreme Court
A hearing panel reviewed an appeal from Wannamoisett County Club, Inc. (Wannamoisett) against a summary judgment granted in favor of Aetna Casualty & Surety Company (Aetna). The core issue was Aetna's obligation to defend or indemnify Wannamoisett and its employee, Christopher Holland, in a lawsuit filed by Malgorzata Wrzesien. Wrzesien alleged sexual harassment and discrimination during her employment from April to October 1993, claiming violations of the Rhode Island Fair Employment Practices Act, Title VII of the Civil Rights Act of 1964, and intentional infliction of emotional distress. Aetna's insurance policy included coverage for workers’ compensation and employers’ liability, but explicitly excluded intentional injuries and damages arising from personnel practices, including harassment and discrimination. The trial justice applied the "pleadings test" established in precedent cases, comparing Wrzesien's allegations with the policy terms and concluded they did not fall within the policy's coverage, as they did not pertain to accidental bodily injury or negligence. Despite Wrzesien's claims of battery, she did not allege any physical bodily injury, which further supported the trial justice's decision. Citing prior rulings, the panel affirmed that Aetna had no duty to defend against claims of emotional harm. Consequently, the appeal by Wannamoisett was denied and dismissed, with the summary judgment from the Superior Court upheld. Judges Lederberg and Bourcier did not participate in the decision.