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American Alternative Insurance v. Metro Paramedic Services, Inc.

Citations: 829 F.3d 509; 41 I.E.R. Cas. (BNA) 913; 2016 U.S. App. LEXIS 12794; 100 Empl. Prac. Dec. (CCH) 45,591; 2016 WL 3741947Docket: No. 15-2310

Court: Court of Appeals for the Seventh Circuit; July 12, 2016; Federal Appellate Court

Narrative Opinion Summary

The case involves a dispute over insurance coverage for a lawsuit alleging severe workplace misconduct, including sexual harassment and assault, against Metro Paramedic Services and Antioch Rescue Squad. The plaintiffs, former employees, accused these entities of fostering a hostile work environment and failing to address their complaints. American Alternative Insurance Corporation (AAIC), which insured Antioch, covered Antioch's defense costs but refused to defend Metro, prompting a legal battle over coverage obligations. The district court ruled in favor of Metro, finding that AAIC had a duty to defend based on the policy's terms and the joint venture relationship between Metro and Antioch. The decision was upheld on appeal, with the court applying Illinois law and the 'eight corners' rule to assess the duty to defend. The court also addressed arguments regarding the policy's exclusion for sexual abuse, determining the allegations fell under covered sexual harassment. Consequently, AAIC was required to defend Metro, affirming the district court's judgment and highlighting the insurer's obligations under the policy.

Legal Issues Addressed

Duty to Defend under Insurance Policy

Application: The court determined that AAIC had a duty to defend Metro in the lawsuit because the allegations in the complaint fell within the policy's coverage.

Reasoning: The district court ruled that AAIC had a duty to defend Metro under its policy, a decision affirmed by the reviewing court.

Interpretation of Insurance Policy under Illinois Law

Application: The court applied Illinois law, focusing on the 'eight corners' rule, which involves comparing the complaint's allegations with the insurance policy terms to determine the duty to defend.

Reasoning: Under Illinois law, an insurer's duty to defend is assessed solely based on the allegations in the underlying complaint, following the 'eight corners' rule.

Joint Venture as Named Insured

Application: The court found that Metro was a named insured under the policy due to its joint venture with Antioch, based on the operational collaboration and shared resources.

Reasoning: The underlying complaint alleges that Antioch and Metro functioned as a joint venture, citing various operational collaborations and shared resources between the two entities.

Sexual Harassment vs. Sexual Abuse Exclusion

Application: The court concluded that the allegations did not meet the policy's definition of sexual abuse and thus were not excluded from coverage; they were considered under sexual harassment, which was covered.

Reasoning: The claim that the sexual-abuse exclusion bars coverage fails, as the allegations do not fit the exclusion's definition of sexual abuse.