Earhart v. Indemnity Insurance Company of North America
3:22-cv-01050
| M.D. La. | Jun 30, 2025Background:
- Plaintiffs (the Earhart family) were involved in a multi-vehicle accident on I-10 in Baton Rouge, Louisiana, largely caused by an 18-wheeler during Hurricane Ida evacuations.
- Plaintiffs alleged personal injuries and sued multiple parties, including several insurance companies, brokers, and claims administrators.
- Relevant defendants (IICNA, Mohave, EMA, Transtar) moved for summary judgment, asserting either lack of liability or that all obligations under insurance had been met.
- IICNA had already paid its $1,000,000 policy limit to Plaintiffs.
- Mohave, EMA, and Transtar argued they did not underwrite insurance or owe any related duties to Plaintiffs.
- Plaintiffs did not oppose the summary judgment motion.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Status of IICNA after policy payment | IICNA issued policy, owes damages | All obligations met, policy limit paid | IICNA dismissed; no further liability |
| Mohave's liability for coverage | Mohave provided coverage | Mohave did not issue policy or procure insurance | Mohave dismissed; no basis for liability |
| EMA & Transtar's duty to supervise | Negligent supervision of driver's employer | They are brokers/administrators with no supervisory duty | EMA & Transtar dismissed; owe no duty to Plaintiffs |
| Basis for remaining in suit post-payment | Defendants should remain as parties | Duties discharged or no duty exists | All four defendants dismissed with prejudice |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard—genuine disputes must be material)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (all inferences at summary judgment viewed in favor of nonmovant)
- Davis v. Counts, 880 So. 2d 968 (La. App. 2d Cir. 2004) (insurance contract sets liability limits)