Michael Vogt v. State Farm Life Insurance Comp
963 F.3d 753
| 8th Cir. | 2021Background
- Michael Vogt represented a ~25,000-member class alleging breach of contract and conversion against State Farm for collection of cost-of-insurance (COI) fees not permitted by policy language.
- A jury returned a $34.3 million verdict for the class; the district court initially denied prejudgment interest.
- This Court in Vogt v. State Farm Life Ins. Co. affirmed the verdict and held Vogt was entitled to prejudgment interest at the 4% contractual rate, and remanded for calculation.
- On remand the district court held a hearing, rejected State Farm’s arguments (damages not liquidated; general verdict ambiguity; double recovery for current policyholders), and awarded $4,521,674.38 in prejudgment interest.
- State Farm appealed again; the Eighth Circuit affirmed, applying the law-of-the-case doctrine to conclude the prior opinion resolved entitlement and liquidated-damages questions and upholding the district court’s reasoning and award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to prejudgment interest / whether damages were liquidated | Vogt: Prior opinion awarded prejudgment interest at contractual 4% — damages therefore liquidated and interest is due | State Farm: Damages were not liquidated; prior opinion did not decide liquidated-damages prerequisite | Court: Law-of-the-case — prior opinion’s grant of prejudgment interest resolved liquidated-damages issue; award affirmed |
| Effect of general verdict mixing contract and conversion claims | Vogt: Victory on contract claim supports prejudgment interest despite conversion claim also succeeding | State Farm: General verdict prevents separating contract damages from conversion (no interest on conversion) | Court: District court correctly awarded interest on contract claim; general verdict did not bar prejudgment interest |
| Double recovery for class members whose policies continued past data cutoff | Vogt: Jury award did not include post-cutoff interest; awarding prejudgment interest does not duplicate recovery | State Farm: Damages model for active policyholders already included contractual interest, so additional prejudgment interest would double-count | Court: District court found no overlap and no double recovery; award stands |
Key Cases Cited
- Vogt v. State Farm Life Ins. Co., 963 F.3d 753 (8th Cir. 2020) (affirmed verdict and held plaintiff entitled to prejudgment interest at contractual 4% rate)
- Child.'s Broad. Corp. v. Walt Disney Co., 357 F.3d 860 (8th Cir. 2004) (standard of review for prejudgment interest; state-law authority reviewed de novo)
- Macheca Transp. Co. v. Phila. Indem. Ins. Co., 737 F.3d 1188 (8th Cir. 2013) (Missouri requires liquidated damages as prerequisite for prejudgment interest)
- Marshall v. Anderson Excavating & Wrecking Co., 8 F.4th 700 (8th Cir. 2021) (explaining the law-of-the-case doctrine and its binding effect on remand)