Anderson v. State Farm Fire & Casualty Company
5:22-cv-00991
| W.D. Okla. | Aug 13, 2024Background
- Plaintiffs Manuel and Cheryl Anderson allege their property was damaged by a storm in October 2021 and submitted a claim under their State Farm home insurance policy.
- State Farm investigated, determined the repair estimate was less than the policy deductible, found no other recent damage, and later argued roof damage predated the policy.
- Plaintiffs filed suit for breach of contract, alleging State Farm wrongly denied coverage for their roofs.
- At issue is Plaintiffs’ First Motion in Limine seeking to bar State Farm from introducing evidence of policy provisions not referenced in its decision or pleaded as affirmative defenses, aside from a "neglect" exclusion.
- Plaintiffs further requested use of Oklahoma’s Unfair Claims Settlement Practices Act to determine admissibility of such evidence.
- The matter was fully briefed by both parties before the Western District of Oklahoma.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Limiting Evidence to Cited Policy Provisions | State Farm should be barred from referencing policy provisions not cited in its claim denial/defenses (except "neglect"), to reflect what was actually considered during claim determination. | The motion is too vague; decisions regarding admissibility should be made during trial in context; Defendant may not need to reference the disputed provisions, but should not be foreclosed pre-trial. | DENIED. The Court found it premature to limit evidence before trial and reserved objections for trial. |
| Application of OUCSPA in Evidentiary Determinations | OUCSPA should guide admissibility of evidence for insurer defenses. | Not directly addressed; argument was the focus should be on evidentiary rulings at trial. | The Court did not explicitly adopt or apply OUCSPA at this stage. |
Key Cases Cited
- Luce v. United States, 469 U.S. 38 (motions in limine provide pretrial opportunity to rule on forecasted evidence relevance; rulings are preliminary)
- United States v. Martinez, 76 F.3d 1145 (district court may change in limine rulings at any time at its discretion)
- Palmieri v. Defaria, 88 F.3d 136 (advance evidentiary rulings help avoid disruption but are usually better made at trial)