Steven Hayne v. The Doctors Company
145 So. 3d 1175
| Miss. | 2014Background
- Dr. Hayne, a Mississippi forensic pathologist, carried a medical malpractice policy with The Doctors from 1987 to 2003.
- Brewer, an exonerated defendant, sued Hayne for malicious prosecution, fraud, and negligent misrepresentation based on Hayne’s testimony and bite-mark analysis.
- The Doctors denied coverage, arguing the policy covered injuries to patients only, and that Brewer’s claim involved a nonpatient.
- The Doctors moved for summary judgment; Hayne argued ambiguity, estoppel, and need for further discovery to determine The Doctors’ knowledge.
- Trial court granted summary judgment, holding the policy unambiguous and excluding Brewer/Edmonds-type claims; the Mississippi Supreme Court affirmed.
- Key issue on appeal was whether the policy language was ambiguous and thus could be construed to provide coverage or whether the language indisputably excluded coverage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the policy language ambiguous regarding coverage for exonerated nonpatient defendants? | Hayne argues ambiguity requires coverage. | The Doctors contends the language is clear and excludes such claims. | Policy language unambiguous; no coverage for exonerated nonpatients. |
| Do governmental employment exclusions apply to Hayne’s Brewer/Edmonds claims? | Hayne contends exclusion should not bar coverage given context. | Exclusion applies to governmental employment scenarios. | Governmental employment exclusion precludes coverage. |
| Can parol evidence or representations alter the written policy terms? | Hayne argues representations created coverage beyond the written terms. | Written policy controls; parol evidence cannot vary terms. | Written policy controls; parol evidence cannot overcome unambiguous terms. |
Key Cases Cited
- Hankins v. Maryland Cas. Co./Zurich American Ins. Co., 101 So. 3d 645 (Miss. 2012) (insurance policy interpretation; ambiguity favors insured when present; language unambiguous controls)
- Architex Ass’n, Inc. v. Scottsdale Ins. Co., 27 So. 3d 1148 (Miss. 2010) (analyzing policy language and interpretive approach)
- J & W Foods Corp. v. State Farm Mut. Auto. Ins. Co., 723 So. 2d 550 (Miss. 1998) (ambiguity resolved in insured's favor; liberal construction where ambiguous)
- Mladineo v. Schmidt, 52 So. 3d 1154 (Miss. 2010) (parol evidence cannot be used to vary written insurance terms; agent misrepresentation imputations)
- Robichaux v. Nationwide Mut. Fire Ins. Co., 81 So.3d 1030 (Miss. 2011) (knowledge of policy terms imputed to insured; unambiguous exclusions)