Alexander v. Motorists Mut. Ins. Co., 2012 Ohio 3911

Alexander, a long-time independent insurance salesperson, worked through various licensed agencies and built a book of business with Motorists-affiliated firms.
In Feb. 2005 Alexander transferred his book to Young Insurance Services, under an Agent and Manager Contract that allowed transfer of the book if not renewed; contract warned of forfeiture of commissions for breach.
Young terminated Alexander’s services effective Sept. 20, 2005, but promised to service his clients until he could transfer or obtain another agency or direct contract.
On Oct. 11, 2005 Motorists demanded that Alexander’s authority with the agency be terminated and that all accounts be transferred to the home office, with no further commissions.
Young transferred Alexander’s accounts to Motorists’ home office and Alexander’s license to write Motorists business was canceled; shortly thereafter Motorists informed clients the agent was no longer licensed, affecting service and renewals.
Alexander later entered a new agency relationship and, while recovering many clients, lost substantial business; the trial court granted summary judgment to Motorists, which the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Motorists was entitled to summary judgment on all claims.	Alexander contends genuine issues exist on conversion.	Motorists argues no genuine issues require trial.	Yes; no genuine issues; judgment affirmed.

Zacchini v. Scripps Howard Broadcasting Co., 47 Ohio St.2d 224 (1976) (definition of conversion elements and ownership rights)
Grant Thornton v. Windsor House, Inc., 57 Ohio St.3d 158 (1991) (third-party beneficiary and contract rights)
Caruso v. Natl. City Mort. Co., 187 Ohio App.3d 329 (2010) (third-party beneficiary framework in Ohio)
Kenty v. Transamerica Premium Ins. Co., 72 Ohio St.3d 415 (1995) (elements of tortious interference with contract)