Meier v. Wadena Insurance Company, 2:23-cv-00158

Plaintiff Margrit Meier d/b/a Hartland Inn sued Wadena Insurance Company over an appraisal-related dispute; the Court dismissed the suit on June 5, 2023 for failure to plausibly state viable claims.
Wadena moved for Rule 11 sanctions, arguing Meier’s challenge to the appraisal process and use of the Broad Evidence Rule was frivolous and ‘‘exceedingly frivolous.’’
Meier based her challenge primarily on Coppins v. Allstate Indemnity Co., a Wisconsin Court of Appeals decision that created some uncertainty about appraisal review and the Broad Evidence Rule.
The Court concluded Meier’s claims aligned more with the Wisconsin Supreme Court’s approach in Farmers Automobile Ins. Ass’n v. Union Pacific R.R. Co., and distinguished Coppins from controlling state precedent.
The Court found Meier’s argument—seeking to extend Coppins to her policy-specific facts—was nonfrivolous, even if ultimately unsuccessful, and that a prior dismissal of a related suit did not render the new filing sanctionable.
For these reasons, the Court denied Wadena’s motion for Rule 11 sanctions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 11 sanctions are warranted for Meier’s suit	Meier argued her claim was a plausible extension of Coppins to her policy’s appraisal/Broad Evidence Rule issue	Wadena argued the suit was meritless and ‘‘exceedingly frivolous,’’ warranting sanctions	Denied — Meier’s legal contentions were nonfrivolous and warranted reasonable inquiry under Rule 11
Whether Coppins supported judicial review of appraisal/Broad Evidence Rule here	Meier relied on Coppins to argue the appraisal use of the Broad Evidence Rule violated her policy rights	Wadena maintained Coppins was inapposite and state supreme court precedent (Farmers) controlled	The Court distinguished Coppins, applied Farmers’ approach, and rejected Meier’s extension but found the argument nonfrivolous
Whether a prior dismissal made the new suit frivolous	Meier contended the new suit raised a distinct, policy-specific question not decided in the prior case	Wadena contended the prior decision foreclosed her claims and counsel should have known the position was groundless	Denied — the new suit raised a similar but distinct issue; prior dismissal did not make the filing sanctionable

Hartmarx Corp. v. Abboud, 326 F.3d 862 (7th Cir. 2003) (Rule 11 sanctions should be imposed sparingly)
Cuna Mut. Ins. Soc’y v. Off. and Pro. Emps. Int’l Union, Loc. 39, 443 F.3d 556 (7th Cir. 2006) (upholding sanctions where arbitration-related challenges are substantially without merit)
Coppins v. Allstate Indemnity Co., 857 N.W.2d 896 (Wis. Ct. App. 2014) (state court decision that introduced uncertainty about appraisal review and Broad Evidence Rule)
Farmers Automobile Ins. Ass’n v. Union Pacific R.R. Co., 768 N.W.2d 596 (Wis. 2009) (Wisconsin Supreme Court’s approach to appraisal review relied upon by the district court)
Nat’l Wrecking Co. v. Int’l Bhd. of Teamsters, Loc. 731, 990 F.2d 957 (7th Cir. 1993) (standards on imposition of sanctions and reasonable inquiry)