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356 P.3d 617
Okla.
2015
Facts & Procedural History
Mid-Continent Casualty Company's Declaratory Action in Tulsa County in February 2008, CJ-2008-1532
American Interstate Insurance Company's Declaratory Action in Federal Court in June 2009
TAYLOR, J., dissenting (joined by Winchester, J.):
Notes

BROOM v. WILSON PAVING & EXCAVATING, INC.

Case Number: 109813

THE SUPREME COURT OF THE STATE OF OKLAHOMA

Decided: 04/07/2015

2015 OK 19

Cite as: 2015 OK 19, __ P.3d __

NOTICE: THIS OPINION HAS NOT BEEN RELEASED FOR PUBLICATION. UNTIL RELEASED, IT IS SUBJECT TO REVISION OR WITHDRAWAL.

STEVEN L. BROOM, Plaintiff-Appellant,
v.
WILSON PAVING & EXCAVATING, INC., an Oklahoma Corporation, Defendant-Appellant,
and
MID-CONTINENT CASUALTY COMPANY, an Oklahoma Corporation, Garnishee-Appellee.

CERTIORARI TO THE COURT OF CIVIL APPEALS, DIVISION IV, ON APPEAL FROM THE DISTRICT COURT OF TULSA COUNTY, STATE OF OKLAHOMA, HONORABLE JEFFERSON D. SELLERS

¶0 In May of 2007, Steven Broom went to the offices of Labor Ready, an employment agency, to secure employment. Broom accepted employment with Labor Ready and was directed to begin work that day for Wilson Paving & Excavating Inc., laying pipe inside a trench. That same afternoon, approximately four hours later, the trench in which Broom was working collapsed, and he suffered serious injuries. Broom pursued and received workers’ compensation benefits from his employer, Labor Ready, for the injuries he sustained in the accident. Broom also sued Wilson Paving for his injuries in a third-party action in the District Court of Tulsa County. The trial court found in favor of Broom and entered judgment against Wilson Paving for $1,150,000.00. Broom then sought post-judgment garnishment of Wilson Paving‘s Commercial General Liability Policy issued by Mid-Continent Casualty Company. The trial court entered summary judgment in favor of Mid-Continent, finding that coverage for Broom‘s injuries was precluded under the “earth movement” exclusion clause in Mid-Continent‘s policy. The Court of Civil Appeals found that the earth movement exclusion clause did not prevent coverage for Broom‘s injuries, but affirmed summary judgment on different grounds. Upon review, we hold Mid-Continent‘s Commercial General Liability Policy provides coverage for Broom‘s injuries.

COCA OPINION VACATED; TRIAL COURT‘S ORDER GRANTING SUMMARY JUDGMENT TO GARNISHEE-APPELLEE MID-CONTINENT CASUALTY COMPANY AFFIRMED IN PART AND REVERSED IN PART; CAUSE REMANDED FOR FURTHER PROCEEDINGS CONSISTENT WITH TODAY‘S PRONOUNCEMENT

Kevin E. Krahl, Fuller Tubb Bickford & Krahl, PLLC, Oklahoma City, OK, for Plaintiff-Appellant Steven L. Broom
Paula J. Quillin, Feldman, Franden, Woodard & Farris, Tulsa, OK, for Defendant-Appellant Wilson Paving & Excavating, Inc.
Dean Foote, Law Offices of Dean Foote, PLC, Tulsa, OK, for Defendant-Appellant Wilson Paving & Excavating, Inc.
James K. Secrest, II, Edward J. Main, Benjamin J. Oxford, Secrest, Hill, Butler & Secrest, Tulsa, OK, for Garnishee-Appellee Mid-Continent Casualty Company

GURICH, J.

Facts & Procedural History

¶1 Wilson Paving & Excavating, Inc. was one of several subcontractors retained to perform services in connection with a renovation project at Sand Springs Memorial Stadium at Charles Page High School. Specifically, Wilson Paving contracted to dig trenches and lay pipe for a storm drainage system being installed under the school‘s athletic field. Wilson Paving utilized a local staffing agency, Labor Ready, to secure temporary workers to assist on the project. On or about May 30, 2007, Steven Broom went to the offices of Labor Ready to obtain employment. Broom was directed by Labor Ready to work with Wilson Paving at Sand Springs High School. He reported to the high school and, at the instruction of Wilson Paving, began work laying pipe inside a trench that was approximately five to six feet deep, four to five feet wide, and fifty feet long.1

¶2 At approximately 2:30 p.m. that same day, the trench in which Broom was working collapsed twice--the first time covering him in dirt to his waist and the second time covering him in dirt to his neck.2 Persons on the job site freed Broom from the neck to the waist while waiting on emergency personnel to arrive.3 Once on the scene, emergency personnel could not enter the trench to rescue Broom until the trench was safely reinforced. During this time, Broom remained buried from the waist down. Emergency personnel eventually removed Broom from the trench, and he was transported to the hospital where he was treated for serious injuries, including rib fractures, collapsed lungs, pulmonary contusions, blood within the chest, fluid around the spleen and kidney, and a left kidney laceration.4

¶3 The record reflects that before the trench collapsed, one of Wilson Paving‘s employees, Jack Bailey, was using a backhoe to dig the trench and to retrieve pipe from an area adjacent to the trench.5 Mr. Bailey would dig a twenty-foot section of trench, then Mr. Bailey, Broom, and another employee of Wilson Paving, Harley Nipper, would place the pipe in the trench. Mr. Bailey would then use the backhoe to put a few feet of dirt on top of the pipe to secure it, while Broom and Mr. Nipper did “the hand work” inside the trench, “leveling it and walking it in.”6 After completing a twenty-foot section, they would repeat the process.7 At some point, either while Mr. Bailey was in the process of digging another twenty-foot section or while he was retrieving pipe, the trench collapsed on Broom while he was working therein.8

¶4 Wilson Paving believed the trench collapse was due to the work of another contractor who had allegedly removed a monument and flag pole near the area of the collapse but failed to alert Mr. Bailey of such before he began digging the trench.9 Wilson Paving believed the removal of such increased the moisture in the soil, causing a latent hazard in the area.10 Upon investigation of the trench collapse, OSHA cited Wilson Paving with five violations including failure to instruct employees in the recognition and avoidance of unsafe conditions, failure to protect employees with protective helmets, lack of safe means of egress out of the trench, failure to place and keep excavated materials at least two feet from the edge of the excavation, and failure to provide an adequate protective system to protect employees in the excavation.11

¶5 Broom pursued and received workers’ compensation benefits from Labor Ready for the injuries he sustained in the accident. Labor Ready was identified as Broom‘s employer in the workers’ compensation action. Wilson Paving was not a party to the action and paid no workers’ compensation benefits to Broom. Broom also sued Wilson Paving for his injuries in a third-party action12 in the District Court of Tulsa County.

Mid-Continent Casualty Company‘s Declaratory Action in Tulsa County in February 2008, CJ-2008-1532

¶6 Wilson Paving purchased a Commercial General Liability Policy from Mid-Continent Casualty Company for the period of April 1, 2007, to April 1, 2008. The policy was in effect at the time of Broom‘s injuries.13 In February of 2008, Mid-Continent filed a declaratory action in Tulsa County, Case No. CJ-2008-1532, seeking a ruling from the district court that it had no duty to defend or indemnify Wilson Paving under the policy with respect to any claims asserted by Broom. At the time of the declaratory judgment action, Broom had not yet sued Wilson Paving in the district court. Upon a renewed Motion for Summary Judgment by Mid-Continent, the Honorable Daman H. Cantrell, found Mid-Continent had a duty to defend Wilson Paving and that “[t]he issue regarding a duty to indemnify [could] be reurged after the matter ha[d] been tried on the merits.”14 Judge Cantrell did not make any determination as to coverage under Mid-Continent‘s policy. Upon motion by Mid-Continent, Judge Cantrell certified the ruling for interlocutory appeal. Mid-Continent petitioned this Court for certiorari review of the certified interlocutory order, Case No. 108,476, but moved to dismiss the petition prior to this Court‘s consideration of the Petition for Certiorari. This Court, in an Order filed October 25, 2010, dismissed Mid-Continent‘s appeal in Case No. 108,476.

¶7 On January 5, 2011, Wilson Paving filed a Motion for Partial Summary Judgment. The trial court, on November 10, 2011, again found Mid-Continent had a duty to defend under the policy but did not make any determination as to coverage under Mid-Continent‘s policy. Upon motion by Mid-Continent, the trial court again certified the order for interlocutory appeal on January 17, 2012. Mid-Continent again filed a Petition for Certiorari to review the certified interlocutory order, which was denied by this Court by Order on March 12, 2012, in Case No. 110,364. The last docket entry in CJ-2008-1532, filed on April 19, 2012, was this Court‘s mandate dismissing the appeal in Case No. 110,364.

American Interstate Insurance Company‘s Declaratory Action in Federal Court in June 2009

¶8 In addition to Mid-Continent‘s Commercial General Liability Policy, Wilson Paving also purchased a Workers’ Compensation and Employers Liability Insurance Policy from American Interstate Insurance Company for the period of October 1, 2006, to October 1, 2007. That policy was also in effect at the time of Broom‘s injuries. On June 3, 2009, AIIC filed a declaratory judgment action in the U.S. District Court for the Northern District of Oklahoma, seeking a declaration regarding its rights and responsibilities under the AIIC policy. Both Wilson Paving and Broom were parties to the action. Mid-Continent was not a party to the action and coverage under the Mid-Continent policy was not at issue. AIIC, Wilson Paving, and Broom agreed that the workers’ compensation insurance coverage provided for in Part One of the AIIC policy did not apply in the case. At issue was Part Two of the policy--the Employers Liability Policy--which applied to bodily injury to an employee of the insured.

¶9 AIIC moved for summary judgment, arguing that although the AIIC policy provided coverage for bodily injury to an employee caused by accident or disease, the AIIC policy specifically excluded from coverage “bodily injury intentionally caused or aggravated by you [the insured].”15 The Honorable James H. Payne found Broom had only alleged intentional conduct in the state court litigation, and as such, Broom‘s injuries were excluded from coverage under AIIC‘s policy because the policy did not cover bodily injury intentionally caused or aggravated by the insured and the “allegations against Wilson Paving, if true [were] clearly not for bodily injury caused by accident or ‘an unknown cause,‘” as required for coverage under the policy.16 The ruling by Judge Payne was not appealed.17

TAYLOR, J., dissenting (joined by Winchester, J.):

¶1 I respectfully dissent from the Court‘s decision. The trial court‘s precise determination of the meaning of the earth-movement exclusion was correct. I write separately to emphasize two serious missteps in the Court‘s construction of this exclusion. To construe the exclusion as ambiguous and interpret it to apply only to naturally occurring earth movement is a torturous reading of its words. The entire case should turn on the purpose of the insurance policy and the plain language of the exclusion. The Court confuses this liability policy with that of a homeowner‘s or all-risk policy and then gives only a passing analysis to the actual language at issue. The judgment entered against Wilson Paving in the trial court may be due and owing, but it is simply not covered by this commercial general liability (CGL) policy.

¶2 Wilson Paving purchased a CGL policy from Mid-Continent as protection from all types of liability claims for bodily injury and/or property damage that may arise from the business‘s premises, products, operations, and other enterprises of the business. Wilson Paving‘s workers’ compensation insurance policy covered its employees while on the job; its CGL policy was to be its public liability policy. Steven Broom was an employee of the temporary agency on the Wilson Paving job site, and he was injured while working inside a trench that caved in. The accident and subsequent injury were fully covered by the temporary agency‘s workers’ compensation coverage, and Broom collected the full measure of what he was entitled for this on-the-job injury.

¶3 The parties added the earth-movement exclusion to the CGL policy as an endorsement which modified the CGL policy coverage. The language of this exclusion is straightforward, but unfortunately misconstrued by the Court:

This insurance does not apply to “bodily injury“, “property damage“, “personal and advertising injury” arising out of, caused by, resulting from, contributed to, aggravated by, or related to earthquake, landslide, mud flow, subsidence, settling, slipping, falling away, shrinking, expansion, caving in, shifting, eroding, rising, tilting or any other movement of land, earth or mud.

The Court disregards its rules of construction and interprets the exclusion as ambiguous because it excludes all earth movement, natural and man-made. The basis for this puzzling conclusion on ambiguity comes from the Court‘s reliance on cases from other jurisdictions, and multiple errors in logic lead the Court to this point.

¶4 First, the cases relied upon by the Court all involve all-risk or homeowner‘s insurance--an entirely different basis for insurance than the CGL policy. Second, the Court only passes at construing the language of the policy and fails to inform the reader just what term is ambiguous. To be generous, the Court confuses a lack of restrictive adjectives in the exclusion for what it says is an ambiguity. The Court chooses not to limit itself to the agreement alone, instead adding restrictive language where the parties did not. See ENI Producing Props. Program Ltd. P‘ship 1982-I ex rel. Baytide Petroleum, Inc. v. Samson Inv. Co., 1999 OK 21, ¶ 17, 977 P.2d 1086, 1089 (“Whether the parties intentionally left out language . . . or unwittingly neglected to account for it, this Court is nonetheless constrained by the agreement.). Third, a majority of the cases the Court discusses actually disagree with the Court‘s conclusion on the ambiguous provision, each concluding that an earth-movement exclusion is not ambiguous.1

¶5 The Court next errs by misapplying the doctrine of reasonable expectations. See Max True Plastering Co. v. U.S. Fid. & Guar. Co., 1996 OK 28, ¶ 1, 912 P.2d 861, 863. The Court relies on the self-serving subjective statements of the insured despite this Court‘s restrictive application of the doctrine of reasonable expectations to only the “objectively reasonable expectations” of a like insured. Id. In hindsight, the insured is always going to allege the existence of coverage when in dispute. Yet Wilson Paving was in the excavating and trenching business, it was a sophisticated company, and it agreed to the endorsement to the CGL policy that added the exclusion. It is perhaps even more telling of the parties’ intent that the exclusion was added as an endorsement, separate and apart from the list of exclusions in the main body of the CGL policy. The Court adopts the insured‘s subjective complaints as reasonable expectations; it then further errs when it agrees that the entire CGL policy is worthless because it does not cover trench cave-ins. This conclusion is unfair and inaccurate as the CGL policy covers a wide range of Wilson Paving‘s possible liabilities. What it specifically does not cover is this cave-in. The Court should refrain from indulging in the subjective complaints of the insured when the language is easily construed and understood and the doctrine of reasonable expectations looks at the objectively reasonable expectations of a like insured.

¶6 If the Court were to devote even a cursory moment to construing the language, the need for the Court‘s tortuous path to its conclusion would be irrelevant. Our rules of contract construction forgo the need to rely on other courts’ decisions. Our “cardinal rule” when examining insurance contracts “is to determine and give effect to the intent of the parties.” In re Kaufman, 2001 OK 88, ¶ 13, 37 P.3d 845, 853. When policy provisions are clear, consistent, and unambiguous, we look to the plain and ordinary meaning of the policy language to determine and give effect to the parties’ intent. Dodson v. St. Paul Ins. Co., 1991 OK 24, ¶ 12, 812 P.2d 372, 376-77; 15 O.S.2011, §§ 152, 154, 160. And the first guidepost we must observe in insurance-contract construction is that “[p]arties are at liberty to contract for insurance to cover such risks as they see fit and they are bound by terms of the contract.” Cranfill v. Aetna Life Ins. Co., 2002 OK 26, ¶ 5, 49 P.3d 703, 707. We are not at liberty to rewrite the terms the parties negotiated. Id. The Court fails to take these rules to heart.

¶7 The policy‘s plain language excludes coverage for any movement of land, earth, or mud. The endorsement applies to events related to earth movement. The cause of those events is not limited by the policy; this Court cannot in turn choose to limit those causes. The plain language establishes that the parties intended to extend this endorsement to earth movement whether natural or man-made. Yet the Court chooses to rewrite the exclusion and to ignore the intent of the parties apparent from the endorsement‘s plain language. The Court must refuse to rewrite policies to create distinctions where no language in the policy exists to support such a distinction. See Max True Plastering, 1996 OK 28, ¶ 20, 912 P.2d at 869 (“In interpreting an insurance contract, this Court will not make a better contract by altering a term for a party‘s benefit.“). By refusing to read the policy language as written, the Court violates this governing tenant for construction of insurance contracts. See id. The Court indulges in a forced and constrained interpretation to reach a result that is repugnant to the plain language of the provision.

¶8 The case before the Court should turn on a simple construction of the endorsement. The earth-movement exclusion bars coverage for bodily injury “arising out of . . . caving in . . . of land, earth or mud.” The endorsement‘s construction is dependent on the definition of the phrase “caving in.” We define words in their ordinary meaning if the policy does not define them. Id. ¶ 19, 912 P.2d at 869. Merriam Webster‘s defines cave as “to fall in or down” or “to cause to fall or collapse.” Merriam Webster, Cave, http://www.merriam-webster.com /dictionary/cave (last visited Mar. 4, 2015). Any injury caused by a cave-in or collapse of land, earth, or mud is excluded here. To quote the Court‘s recitation of facts: “At approximately 2:30 p.m. that same day, the trench in which Broom was working collapsed twice . . . .” The cause of Broom‘s injuries is excluded from coverage under the endorsement to the Mid-Continent CGL policy. I refuse to rewrite this policy.

Citationizer Summary of Documents Citing This Document


CiteNameLevel
None Found.

Citationizer: Table of Authority


CiteNameLevel
Oklahoma Supreme Court Cases
CiteNameLevel
1991 OK 24, 812 P.2d 372, 62 OBJ 802Dodson v. St. Paul Ins. Co.Discussed at Length
1936 OK 748, 63 P.2d 753, 178 Okla. 576KILE v. KILEDiscussed
2001 OK 88, 37 P.3d 845, 72 OBJ 3061IN RE: KAUFMANDiscussed
1918 OK 367, 174 P. 1036, 68 Okla. 301ST. LOUIS & S. F. R. CO. v. BOUSHDiscussed
2002 OK 26, 49 P.3d 703CRANFILL v. AETNA LIFE INS. CO.Discussed
2003 OK 66, 73 P.3d 865SPEARS v. SHELTER MUTUAL INSURANCE COMPANYDiscussed at Length
2003 OK 77, 78 P.3d 93HAMMOCK v. UNITED STATESDiscussed
2005 OK 54, 127 P.3d 572PARRET v. UNICCO SERVICE COMPANYDiscussed at Length
1996 OK 28, 912 P.2d 861, 67 OBJ 806Max True Plastering Co. v. U.S. Fidelity and Guar. Co.Discussed at Length
2006 OK 35, 172 P.3d 193HAWORTH v. JANTZENDiscussed at Length
2010 OK 31, 232 P.3d 458STATE ex rel. OKLAHOMA CORPORATION COMMISSION v. McPHERSONDiscussed
2013 OK 48, 306 P.3d 544SHEFFER v. CAROLINA FORGE COMPANY, L.L.C.Discussed
2014 OK 42, 328 P.3d 1192SMITH v. CITY OF STILLWATERDiscussed
1998 OK 24, 956 P.2d 887, 69 OBJ 1172MILLER v. MILLERDiscussed at Length
1998 OK 75, 963 P.2d 572, 69 OBJ 2620Wynn v. Avemco Insurance Co.Discussed
1999 OK 21, 977 P.2d 1086, 70 OBJ 1004ENI Producing Properties Program Limited Partnership 1982-I v. Sampson Investment Co.Discussed
Title 12. Civil Procedure
CiteNameLevel
12 O.S. 1031District Court, Power to Vacate or Modify its Judgments, WhenCited
12 O.S. 1033Proceedings to Vacate or Modify Judgment or Order - Grounds - by Petition - Verification - SummonsCited
12 O.S. 1038Proceedings to Vacate or Modify a Judgment, Decree or OrderCited
Title 15. Contracts
CiteNameLevel
15 O.S. 152Interpreted to Give Effect to Mutual Intention of PartiesCited
Title 85. Workers’ Compensation
CiteNameLevel
85 O.S. 11Repealed by Laws 2011, SB 878, c. 318, § 87Cited
85 O.S. 12Repealed by Laws 2011, SB 878, c. 318, § 87Cited
85 O.S. 44Repealed by Laws 2011, SB 878, c. 318, § 87Cited

Notes

1
Record on Accelerated Appeal, Ex. 13 at Ex. W (Petition at 2). See Peters Twp. Sch. Dist. v. Hartford Acc. & Indem. Co., 833 F.2d 32, 38 (3d Cir. 1987); Fayad v. Clarendon Nat. Ins. Co., 899 So. 2d 1082, 1088 (Fla. 2005); Henning Nelson Const. Co. v. Fireman‘s Fund Am. Life Ins. Co., 383 N.W.2d 645, 652 (Minn. 1986); Rankin ex rel. Rankin v. Generali--U.S. Branch, 986 S.W.2d 237, 240 (Tenn. Ct. App. 1998).
2
Id. (Petition at 2-3).
3
Id.
4
Id.
5
Record on Accelerated Appeal, Ex. 13, at Ex. 12 (Deposition of Jack Bailey at 29-36).
6
Id. (Deposition of Jack Bailey at 128-29).
7
Id. (Deposition of Jack Bailey at 38-40, 129).
8
Id. (Deposition of Jack Bailey at 69-70).
9
Record on Accelerated Appeal, Ex. 13 at Ex. X (Deposition of Art Wilson at 65-66).
10
Id. (Deposition of Art Wilson at 66).
11
Id. (Deposition of Art Wilson at 17-19). Wilson Paving paid the OSHA citations and did not appeal. Id.
12
See 85 O.S. Supp. 2005 § 44, which provides in part: (a) If a worker entitled to compensation under the Workers’ Compensation Act is injured or killed by the negligence or wrong of another not in the same employ, such injured worker shall, before any suit or claim under the Workers’ Compensation Act, elect whether to take compensation under the Workers’ Compensation Act, or to pursue his remedy against such other. Such election shall be evidenced in such manner as the Administrator may by rule or regulation prescribe. If he elects to take compensation under the Workers’ Compensation Act, the cause of action against such other shall be assigned to the insurance carrier liable for the payment of such compensation, and if he elects to proceed against such other person or insurance carrier, as the case may be, the employer‘s insurance carrier shall contribute only the deficiency, if any, between the amount of the recovery against such other person actually collected, and the compensation provided or estimated by the Workers’ Compensation Act for such case.
13
The policy applicable to Broom‘s accident was a renewal of the policy based upon the same coverage of grading of land construction for which Wilson Paving paid the same premium the year before. Record on Accelerated Appeal, Ex. 14 (Defendant Wilson Paving & Excavating, Inc. Motion to Reconsider at 1).
14
Record on Accelerated Appeal, Ex. 6 at Ex. 9 (Order, CJ-2008-1532 (Nov. 18, 2009)).
15
Record on Accelerated Appeal, Ex. 6 at Ex. 20 (American Interstate Insurance Company Policy at 3).
16
Record on Accelerated Appeal, Ex. 9 at Ex. A (Opinion and Order at 10, Am. Interstate Ins. Co. v. Wilson Paving & Excavating, Inc. and Steven L. Broom, Case No. 09-CV-342-JHP (N.D.O.K. June 25, 2010)). As we discuss below, we disagree with Judge Payne‘s assessment of Broom‘s claims against Wilson Paving in the district court. Broom alleged intentional conduct on the part of Wilson Paving under Parret v. Unicco Serv. Co., 2005 OK 54, 127 P.3d 572, as well as negligence and negligence per se on the part of Wilson Paving. See Record on Accelerated Appeal, Ex. 13 at Ex. W (Petition at 5); Record on Accelerated Appeal, Ex. 7 at Ex. 21 (Pre-Trial Conference Order at 3). Further, we conclude that Broom was not an employee of Wilson Paving, and therefore, no coverage would be available for a non-employee under the AIIC policy.
17
Record on Accelerated Appeal, Ex. 8 (Garnishee‘s Preliminary Response in Opposition to Plaintiff‘s Motion for Summary Judgment at 14).
18
Record on Accelerated Appeal, Ex. 13 at Ex. W (Petition at 5).
19
Record on Accelerated Appeal, Ex. 13 at Ex. W (Petition at 4).
20
Record on Accelerated Appeal, Ex. 9 at Ex. A (Opinion and Order at 4, Am. Interstate Ins. Co. v. Wilson Paving & Excavating, Inc. and Steven L. Broom, Case No. 09-CV-342-JHP (N.D.O.K. June 25, 2010)).
21
Record on Appeal, Ex. 2 (Journal Entry of Judgment at 1).
22
Record on Appeal, Ex. 20 (Order of Summary Judgment at 2) (emphasis added).
23
Smith v. City of Stillwater, 2014 OK 42, ¶ 10-11, 328 P.3d 1192, 1196-97.
24
Record on Accelerated Appeal, Ex. 6 at Ex. 20 (American Interstate Insurance Company Policy at 1-2) (emphasis added).
25
Record on Accelerated Appeal, Ex. 6 at Ex. 20 (American Interstate Insurance Company Policy at 2) (emphasis added).
26
Record on Accelerated Appeal, Ex. 6 at Ex. 1 (Mid-Continent Commercial Lines Policy at 19-20).
27
Record on Accelerated Appeal, Ex. 11 at Ex. 8 (Defendant Wilson Paving & Excavating, Inc., Response to Plaintiff‘s Motion to Reconsider and Renewed Motion for Summary Judgment and Defendant‘s Motion for Rule 13(d) Relief at 1).
28
Record on Accelerated Appeal, Ex. 11 at Ex. 1 (Letter from Arthur Wilson to Doug Sawyer dated June 25, 2010).
29
See Counter-Petition in Error, Ex. C at 1.
30
Record on Accelerated Appeal, Ex. 8 (Garnishee‘s Preliminary Response in Opposition to Plaintiff‘s Motion or Summary Judgment at 15).
31
We also note that the language of the exclusion in the American Interstate policy excludes from coverage “bodily injury intentionally caused or aggravated by you,” whereas Mid-Continent‘s policy excludes from coverage “‘[b]odily injury’ or ‘property damage’ expected or intended from the standpoint of the insured.” This exclusionary language is not identical, and case law from other jurisdictions reveals that such differences in language can be dispositive in determining whether coverage exists under the particular facts of a case. Compare Royal Indmen. Co. v. Soneco/Northeastern Inc., 183 F.Supp.2d 526 (D. Conn. 2002) (finding policy excluding from coverage “bodily injury intentionally caused or aggravated by you” did not preclude coverage for employee‘s injuries when no proof that employer actually engaged in conduct with the intent of causing the injuries) with Holz-Her U.S., Inc. v. U.S. Fid. and Guar. Co., 539 S.E. 2d 348 (finding policy that excluded from coverage injuries “expected or intended from the insured‘s point of view” precluded coverage when such purposeful and intentional acts were so substantially certain to cause injury and damage that one could infer an intent to injure).
32
Record on Accelerated Appeal, Ex. 12 at 3-4 (Garnishee‘s Supplemental Response in Opposition to Plaintiff‘s Motion for Summary Judgment at 3-4). Mid-Continent argues that if Broom was an employee of Wilson Paving at the time of the incident, Broom‘s only recovery against Wilson Paving in the district court was for an intentional tort under Parret v. Unicco Serv. Co., 2005 OK 54, 127 P.3d 572.
33
Record on Accelerated Appeal, Ex. 9 at Ex. A (Am. Interstate Ins. Co. v. Wilson Paving & Excavating, Inc. and Steven L. Broom, Case No. 09-CV-342-JHP at 5 (N.D.O.K. June 25, 2010). It is clear there would be no coverage under the AIIC policy if Broom was not an employee of Wilson Paving. Broom‘s counsel alleged alternative legal theories as to Broom‘s status since neither one of Wilson Paving‘s insurers admitted coverage.
34
Miller, 1998 OK 24, ¶ 26, 956 P.2d at 897.
35
Record on Accelerated Appeal, Ex. 2 (Journal Entry of Judgment at 1) (emphasis added).
36
Record on Accelerated Appeal, Ex. 6 at Ex. 1 (Mid-Continent Commercial Lines Policy at 32) (emphasis added).
37
Record on Accelerated Appeal, Ex. 20 (Order of Summary Judgment at 2) (emphasis added).
38
See Counter-Petition in Error, Ex. C at 3-4.
39
See Record on Accelerated Appeal, Ex. 6 at Ex. 1 (Mid-Continent Commercial Lines Policy at Form ML 12 76 (11 03)).
40
See also Haworth v. Jantzen, 2006 OK 35, ¶ 17, 172 P.3d 193, 197 (“When an insurer desires to limit its liability under a policy, it must employ language that clearly and distinctly reveals its stated purpose.“).
41
See 85 O.S. Supp. 2006 § 11; 85 O.S. Supp. 2005 § 12. Broom and Wilson Paving argue that Broom‘s cause of action against Wilson Paving under Parret v. Unicco Serv. Co., 2005 OK 54, 127 P.3d 572, was only if Broom was determined to be an employee of Wilson Paving at the time of the incident. If Broom was not an employee of Wilson Paving at the time of the incident, Broom and Wilson Paving argue Broom‘s cause of action against Wilson Paving was for negligence. “[A] party litigant may plead, and rely on at trial, alternative and inconsistent theories or defenses under the Oklahoma Pleading Code.” State ex rel. Oklahoma Corp. Comm‘n v. McPherson, 2010 OK 31, ¶ 22, 232 P.3d 458, 464.
42
Record on Accelerated Appeal, Ex. 8 (Garnishee‘s Preliminary Response in Opposition to Plaintiff‘s Motion for Summary Judgment at 3); Answer of Appellee Mid-Continent Casualty Company to Joint Petition for Certiorari at 1.
43
Record on Accelerated Appeal, Ex. 6 at Ex.3 (Defendant Steven L. Broom‘s Response to Plaintiff‘s Motion to for Summary Judgment, Ex. 1).
44
Record on Accelerated Appeal, Ex. 13 AT Ex. W (Petition at 5) (emphasis added).
45
Record on Accelerated Appeal, Ex. 7 at Ex. 21 (Pre-Trial Conference Order at 3).
46
Record on Accelerated Appeal, Ex. 2 (Journal Entry of Judgment at 1) (emphasis added).
47
Record on Accelerated Appeal, Ex. 20 (Order of Summary Judgment at 2) (emphasis added). Mid-Continent‘s insurance policy provided coverage for “‘bodily injury or ‘property damage’ . . . caused by an ‘occurrence’ that takes place in the ‘coverage territory.‘” Record on Accelerated Appeal, Ex. 6 at Ex. 1 (Mid-Continent Commercial Lines Policy at 19). “Occurrence” is defined under the policy as “an accident, including continuous or repeated exposure to substantially the same general harmful conditions.” Record on Accelerated Appeal, Ex. 6 at Ex. 1. (Mid-Continent Commercial Lines Policy at 31).
48
Because the trial court found Broom was a temporary worker for Wilson Paving and not its employee, it was not necessary for the trial court to decide whether Wilson Paving acted with knowledge that injury to Broom was substantially certain to occur under Parret. Any finding or pronouncement in this regard by the trial court was surplusage.
49
Record on Accelerated Appeal, Ex. 6 at Ex. 1 (Mid-Continent Commercial Lines Policy at 19-20).
50
Record on Accelerated Appeal, Ex. 6 at Ex. 6 (Defendant Wilson Paving & Excavating, Inc., Response to Plaintiff‘s Motion to Reconsider and Renewed Motion for Summary Judgment and Defendant‘s Motion for Rule 13(d) Relief at Ex. 4).
51
See also Winters v. Charter Oak Fire Ins. Co., 4 F. Supp.2d 1288 (D.N.M. 1998) (holding that earth movement exclusion in all-risk insurance policy applies only when such movement is due to naturally occurring causes); Opsal v. United Servs. Auto. Ass‘n, 10 Cal. Rptr. 2d 352 (Cal. Ct. App. 1991) (holding that in the context of other exclusions such as earthquakes and volcanic eruptions, the earth movement exclusion must only apply to naturally occurring earth movement); Peters Twp. Sch. Dist. v. Hartford Accident and Indem. Co., 833 F.2d 32 (3d Cir. 1987) (finding that earth movement exclusion in all-risk insurance policy was meant to deny coverage for spontaneous, natural, catastrophic earth movement, and not movement brought about by other causes); United Nuclear Corp. v. Allendale Mut. Ins. Co., 709 P.2d 649 (N.M. 1985) (construing the term earth movement to cover only “naturally occurring phenomenon“); Gullet v. St. Paul Fire & Marine Ins. Co., 446 F.2d 1100 (7th Cir. 1971) (holding that the term “or other earth movement” was limited to the prior types of naturally occurring earth movement specified in the exclusion).
52
See also Steel v. Statesman Ins. Co., 607 A.2d 742 (Pa. 1992) (concluding the earth movement exclusion in an all-risk homeowners’ insurance policy was ambiguous and construing the language of the contract in favor of the insured to exclude coverage for damages from earth movement due to natural events only); Bly v. Auto Owners Ins. Co., 437 So.2d 495 (Ala. 1983) (concluding the earth movement exclusion in homeowners’ insurance policy was ambiguous “at best” as to whether vibrations caused by heavily loaded logging trucks on a nearby road constituted earth movement and holding that the trial court should have construed the exception narrowly to conclude that damages from the vibrations were not excluded from coverage); Peach State Unif. Serv. Inc. v. American Ins. Co., 507 F.2d 996 (5th Cir. 1975) (concluding the earth movement exclusion was ambiguous and holding that the exclusion referred only to “phenomena related to forces operating within the earth itself“); Wis. Builders, Inc. v. Gen. Ins. Co. of America, 221 N.W.2d 832 (Wis. 1974) (finding that the earth movement exclusion contained ambiguities and concluding that the provision applied only to naturally occurring earth movement).
53
Record on Accelerated Appeal, Ex. 11 at Ex. 1 (Letter from Arthur Wilson to Doug Sawyer dated June 25, 2010).
54
Id.
55
Record on Accelerated Appeal, Ex. 14 (Defendant Wilson Paving & Excavating, Inc. Motion to Reconsider, Ex. 2 at 28-29).
56
Record on Accelerated Appeal, Ex. 6 at Ex. 1 (Mid-Continent Commercial Lines Policy at 3).
57
Record on Accelerated Appeal, Ex. 14 (Defendant Wilson Paving & Excavating, Inc. Motion to Reconsider, Ex. 3 at 56).
58
At issue in the case was National Fire‘s duty to defend under its commercial general liability policy issued to the grading contractor. Id. at *1.
59
Record on Accelerated Appeal, Ex. 14 (Defendant Wilson Paving & Excavating, Inc. Motion to Reconsider, Ex. 2 at 28-29).
60
Record on Accelerated Appeal, Ex. 14 (Defendant Wilson Paving & Excavating, Inc. Motion to Reconsider at 4).
61
Other courts have also concluded that the “regardless of cause” language included in the State Farm policies at issue unambiguously excluded earth movements due to man-made causes. See e.g., Chase v. State Farm Fire and Cas. Co., 780 A.2d 1123, 1126 (D.C. Cir. 2001) (freezing of a pipe and failure of a sump pump caused collapse of home); Boteler v. State Farm Cas. Ins. Co., 876 So.2d 1067, 1068-69 (Miss. Ct. App. 2004) (leaking pipe caused foundation to shift resulting in damage to interior); Alf v. State Farm Fire and Cas. Co., 850 P.2d 1272, 1273 (Utah 1993) (freezing of main water line causing extensive flooding and soil erosion on homeowner‘s property).
62
See also Liebel v. Nationwide Ins. Co. of Fla, 22 So.3d 111 (Fla. Dist. Ct. App. 2009) (concluding that the earth movement exclusion in insured‘s all-risk policy unambiguously excluded coverage of damage to insured‘s home caused when soil erosion from a ruptured water line beneath the home caused the foundation to settle; exclusion specifically excepted damage caused by “earth movement due to natural or unnatural causes,” and the water line rupture was an unnatural cause that resulted in earth movement).
63
See Counter-Petition in Error, Ex. C at 2-3.
64
At the summary judgment hearing, the following exchange took place:

The Court: Let me ask you this: And I‘m going to let you make whatever record you want. Do you claim that there‘s any--well, what is your theory of why I should allow you to attack a judgment that‘s been final in this Court? What is your theory in that regard? As a garnishee who has chosen--who probably has the capability--in fact, I‘ve seen it in a least one case, where the Supreme Court allowed an insurance company garnishee to seek to vacate a judgment. You‘ve chosen not to vacate the judgment here. You‘ve chosen really, to make your stand on the--policy, and I --itself--

Mr. Main: Yes.

The Court: [B]ut do you claim that there‘s some case that would--that would allow you to attack a judgment that‘s final?

Mr. Main: Well, the case would--would be the ones which would allow us to attack a judgment which is not--which is not fair or which is unreasonable, and the reason we contend that this judgment is unreasonable is that we contend it is internally inconsistent and contrary to law.

Record on Accelerated Appeal, Ex. 24 (Transcript of Proceedings at 15-16 (April 5, 2011)).
65
See 12 O.S. § 1031; 12 O.S. § 1033; 12 O.S. § 1038.

Case Details

Case Name: BROOM v. WILSON PAVING & EXCAVATING, INC.
Court Name: Supreme Court of Oklahoma
Date Published: Apr 7, 2015
Citations: 356 P.3d 617; 2015 OK 19
Court Abbreviation: Okla.
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