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Land O' Lakes, Inc. v. Employers Insurance

Citation: 528 F. App'x 685Docket: Nos. 12-1887, 12-1889

Court: Court of Appeals for the Eighth Circuit; August 29, 2013; Federal Appellate Court

Narrative Opinion Summary

In this case, the Environmental Protection Agency (EPA) pursued Land O’ Lakes, Inc. for cleanup costs related to chemical spills at a refinery in Oklahoma. Land O’ Lakes sought defense and indemnification from its insurers, Employers Insurance Company of Wausau and Travelers Indemnity Company, both of which denied the claims, leading Land O’ Lakes to sue for coverage. In response, Wausau and Travelers filed third-party claims against White Mountains Reinsurance Company, seeking contribution under prior policies. The district court granted summary judgment to the insurers, holding that Land O’ Lakes’s claims were barred by the applicable six-year statute of limitations. Land O’ Lakes appealed the decision, but the appellate court affirmed the summary judgment, maintaining that neither Wausau nor Travelers was obligated to defend or indemnify Land O’ Lakes. Consequently, White Mountains's appeal concerning its potential contribution liability was dismissed as moot since the primary insurers were not held liable. This case underscores the critical importance of adhering to statutory deadlines in insurance litigation.

Legal Issues Addressed

Contribution Claims among Insurers

Application: Wausau and Travelers sought contribution from White Mountains, but the court found such claims moot upon affirming the summary judgment in favor of Wausau and Travelers.

Reasoning: White Mountains appealed separately, arguing that even if the court reversed Land O’ Lakes's appeal, it still would not be liable for equitable contribution.

Indemnification and Defense Obligations of Insurers

Application: Land O’ Lakes sought defense and indemnification from its insurers, but the court ruled that the insurers had no such obligations.

Reasoning: Land O’ Lakes denied liability but sought defense and indemnification from two insurers... Both insurers refused to defend the claim.

Statute of Limitations in Insurance Claims

Application: The district court determined that Land O’ Lakes's claims against its insurers were time-barred by a six-year statute of limitations.

Reasoning: The district court granted summary judgment in favor of Wausau, Travelers, and White Mountains, ruling that Land O’ Lakes’s claims were barred by a six-year statute of limitations.