St. Paul Fire and Marine Insurance Company v. Kinsale Insurance Company
1:20-cv-00967
| E.D. Cal. | Jul 30, 2025Background
- The case involves three insurance companies—St. Paul Fire and Marine, New York Marine and General, and Kinsale—disputing their respective duties to cover legal defense costs for TRC Operating Company, Inc. and TRC Cypress Group, LLC (collectively, TRC).
- The underlying dispute arises from a state court lawsuit where TRC sued Chevron USA, Inc., and Chevron filed crossclaims against TRC alleging environmental property damage.
- St. Paul and New York Marine both seek a declaration that Kinsale has a duty to defend TRC in the underlying lawsuit; New York Marine also seeks to determine whether Kinsale must indemnify TRC if Chevron prevails on its crossclaims.
- The indemnity issue is currently stayed pending the resolution of the underlying case against TRC.
- The parties jointly requested a stay of these federal proceedings in anticipation of mediation scheduled to occur by August 31, 2025.
- The court granted the stay to promote judicial economy, efficiency, and conserve party and court resources while mediation occurs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether litigation should be stayed pending mediation | Proceeding wastes resources; mediation may resolve issues | Stipulated—no opposition | Stay granted pending mediation |
| Possible prejudice or hardship from stay | No significant delay; parties remain in status quo | No opposition to stay | Stay causes no improper hardship |
| Judicial economy from staying case | Stay avoids unnecessary litigation expenses | No opposition; agrees with efficiency | Judicial economy supports a stay |
| Approach to future case management post-mediation | Status to be reported after mediation | Status to be reported after mediation | Parties must provide post-mediation report |
Key Cases Cited
- Landis v. N. Am. Co., 299 U.S. 248 (1936) (courts have inherent power to control their dockets and may stay proceedings for judicial economy)
- Lockyer v. Mirant Corp., 398 F.3d 1098 (9th Cir. 2005) (standards for granting a stay when competing interests are present)
- CMAX, Inc. v. Hall, 300 F.2d 265 (9th Cir. 1962) (lists factors courts should weigh in granting a stay)
- Yong v. I.N.S., 208 F.3d 1116 (9th Cir. 2000) (length and justification for stays must be weighed carefully)