State Farm Mutual Automobile Insurance Company v. Havemeier

Background

State Farm sought a declaratory judgment about its obligation to provide insurance coverage benefits under a policy covering a 1992 Pontiac Grand Prix owned by its insured, Nikki Blank. Tyler Havemeier was driving the vehicle when it struck Jacob Gatzlaff on June 27, 2016. The parties agreed that Havemeier was an insured under the policy and that Gatzlaff suffered bodily injury.

The policy provided coverage for damages an insured became legally liable to pay because of bodily injury, but excluded coverage for an insured who intentionally caused bodily injury or property damage. Gatzlaff had sued Havemeier in state court for damages arising from the incident, and that lawsuit had been tendered to State Farm for defense and indemnity.

Havemeier had entered an Alford plea to second-degree assault under Minnesota law. An Alford plea allows a defendant to plead guilty while maintaining a protestation of innocence, when the record contains evidence that could support a conviction. During the plea proceeding, Havemeier admitted that his vehicle made contact with Gatzlaff and that he drove away, but he did not expressly admit that he intentionally struck Gatzlaff. The plea transcript also included statements that he disputed the evidence while acknowledging that a jury could convict him if it believed certain witnesses.

State Farm’s motion

State Farm argued that the Alford plea and the factual basis for it conclusively established that Havemeier intended to injure Gatzlaff. State Farm also argued that collateral estoppel—a rule that can prevent a party from relitigating an issue already decided—barred reconsideration of Havemeier’s intent.

The court rejected summary judgment based on the Alford plea. It explained that Minnesota decisions do not always treat an Alford plea like a conventional guilty plea in later civil proceedings. The plea showed that Havemeier faced evidence supporting a criminal conviction, but the conflicting statements in the plea transcript did not establish as a matter of law that he intended to harm Gatzlaff.

The court also rejected State Farm’s collateral-estoppel argument. It concluded that the requirements for applying that rule were not satisfied, including because Gatzlaff was not a party to the criminal proceeding and did not have an opportunity to present his case there. The court further relied on Minnesota authority holding that an insured’s criminal conviction generally cannot be used to prevent a crime victim from litigating intent in a later insurance dispute involving an intentional-act exclusion. The court denied State Farm’s motion for summary judgment.

Gatzlaff’s motion

Gatzlaff argued that the court should grant judgment in his favor because the evidence showed, at most, negligent or careless conduct and did not prove that Havemeier intended to hit or injure him. State Farm argued that intent could be inferred as a matter of law because Havemeier accelerated and steered the vehicle toward Gatzlaff, making injury substantially certain.

Under Minnesota law, an intentional-act exclusion generally applies when the insured specifically intended to cause injury. A court may infer intent as a matter of law from the circumstances when the conduct was calculated and remorseless or when the insured knew, or should have known, that harm was substantially certain to result. Whether that inference is appropriate depends on the facts of each case.

The court found substantial factual disputes. Some testimony supported the conclusion that Havemeier accelerated and swerved toward Gatzlaff. Other testimony supported Havemeier’s account that Gatzlaff ran toward the vehicle and that Havemeier tried to swerve away. The conflicting testimony also raised witness-credibility issues, which a court may not resolve on summary judgment. Although the court stated that a fact-finder could infer intent if it believed some witnesses, it declined to make that inference on the disputed record. The court denied Gatzlaff’s motion for summary judgment.

Disposition

The court ordered that State Farm’s Motion for Summary Judgment was DENIED and Jacob Gatzlaff’s Motion for Summary Judgment was DENIED. The order left unresolved whether the policy’s intentional-injury exclusion applies and whether State Farm must provide coverage in the state-court action.