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Certain Underwriters at Lloyds of London v. Evans

Citation: 896 F.2d 1255Docket: Nos. 87-2851, 88-1230

Court: Court of Appeals for the Tenth Circuit; February 22, 1990; Federal Appellate Court

Narrative Opinion Summary

The case involves two appeals concerning jurisdictional and insurance coverage issues. In Case No. 88-1230, Harvey Young Airport (HYA) failed to file a timely notice of appeal following a district court's summary judgment in favor of Certain Underwriters at Lloyds of London. The district court improperly granted HYA an extension beyond the limits prescribed by Federal Rules of Appellate Procedure, rendering the appeal jurisdictionally invalid. Consequently, HYA's appeal was dismissed for lack of jurisdiction. Case No. 87-2851 involved Lee Ann Evans, representing an estate in a wrongful death action, challenging a summary judgment favoring the Underwriters who asserted an exclusion in their policy. The court affirmed the district court's decision, holding that the decedent was a 'passenger' under the insurance policy's exclusionary terms due to his non-operational status in the aircraft. The ruling was based on the aircraft's direct use in the Fly-In event and the clear language of the insurance policy, resulting in a denial of coverage. Both appeals concluded with reaffirmation of the lower court's decisions, underscoring adherence to procedural rules and substantive insurance policy interpretation.

Legal Issues Addressed

Extension of Time to File Notice of Appeal under Federal Rules

Application: HYA's request for an extension was deemed improper as it exceeded the allowable 10-day extension after the initial 30-day period for filing an appeal.

Reasoning: The district court's granting of HYA's Rule 4(a)(5) motion for an extension of time to file a notice of appeal was improper because it exceeded the allowable 10-day extension set by appellate rules.

Interpretation of Exclusionary Language in Insurance Policies

Application: The court affirmed that the insurance policy's exclusion applied because the aircraft was 'used directly' in the Fly-In event, aligning with the policy terms.

Reasoning: It is undisputed that the Breezy was 'used directly' in the Fly-In.

Jurisdictional Requirement for Timely Notice of Appeal

Application: The court held that HYA's notice of appeal was untimely and therefore jurisdictionally invalid, as it was filed beyond the permissible extension period.

Reasoning: The court concurs, emphasizing that jurisdiction requires a timely notice of appeal, as mandated by the rules.

Passenger Definition in Insurance Policy Exclusion

Application: The court ruled that the decedent was a 'passenger' under the insurance policy terms, as he occupied the rear seat of the aircraft and had no control over it.

Reasoning: The court found that since the decedent occupied the rear seat of the aircraft and had no control over it, he qualified as a passenger.