State Farm Mutual Automobile Insurance Company v. Havemeier
- Elizabeth Wright
- 0:18-cv-02459
- U.S. District Court · District of Minnesota
- 17
In State Farm v. Havemeier, Judge Wright held that an intentional-injury exclusion barred insurance coverage for injuries caused when Havemeier struck Gatzlaff with a vehicle.
State Farm was relieved of any duty to defend or indemnify Tyler Havemeier for Gatzlaff’s injuries under the policy. The ruling concerned Havemeier’s coverage claim and State Farm’s declaratory claims involving Havemeier and Nikki Blank; Gatzlaff’s injury claim was the event underlying the coverage dispute.
What happened
State Farm Mutual Automobile Insurance Company and Jacob Gatzlaff sought declarations about whether State Farm had to cover injuries Gatzlaff suffered after Tyler Havemeier drove a vehicle into him outside a bar. State Farm insured the vehicle and agreed that Havemeier was covered and liable for Gatzlaff’s injuries.
The court found that Havemeier intentionally swerved and accelerated toward Gatzlaff after a verbal argument. Under the policy, State Farm did not have to cover an insured who intentionally caused bodily injury. The court ruled that this exclusion applied and that State Farm had no duty to defend or pay for Havemeier’s liability for the injuries.
Judge Wright also ruled that Havemeier’s guilty plea, entered while maintaining his innocence, was not by itself conclusive proof of intent to injure. The court ordered the no-duty declaration and directed State Farm to file a notice dismissing its claims concerning Havemeier and Nikki Blank.
The detailed version
- State Farm Mutual Automobile Insurance Company v. Havemeier · No. 0:18-cv-02459
- Elizabeth Wright
- Sept. 21, 2021
Background
State Farm and Jacob Gatzlaff each sought a declaratory judgment about State Farm’s obligation to provide insurance benefits under a policy covering Nikki Blank’s 1992 Pontiac Grand Prix, which Tyler Havemeier was driving when the vehicle struck Gatzlaff on June 27, 2016. State Farm conceded that it insured the vehicle, that Havemeier was covered under the policy, that Gatzlaff was injured, and that Havemeier was liable for causing the injuries.
The policy promised to pay damages an insured became legally liable to pay because of bodily injury. It also excluded coverage for an insured who intentionally caused bodily injury or property damage. The court held a bench trial and considered conflicting testimony about whether Havemeier accidentally struck Gatzlaff or intentionally swerved toward him.
Court’s Findings
The court credited testimony from Goblirsch and Erickson that Havemeier accelerated and swerved the vehicle toward Gatzlaff after Gatzlaff made a gesture, struck Gatzlaff hard enough to send him over the vehicle and damage the passenger-side mirror, and then left without stopping. The court found Havemeier’s account—that Gatzlaff unexpectedly ran into the vehicle and that Havemeier did not intend to hit him—not credible.
Havemeier had pleaded guilty to second-degree assault with a deadly weapon through an Alford plea, which is a guilty plea entered while the defendant maintains innocence but acknowledges that the prosecution has evidence supporting guilt. The court ruled that this plea was not conclusive proof that Havemeier intended to injure Gatzlaff.
Legal Analysis
Applying Minnesota law, the court explained that an insurer must prove that an exclusion applies and that exclusions are read narrowly against the insurer. Minnesota law generally requires specific intent to cause injury for an intentional-act exclusion, but intent may be inferred as a matter of law when the circumstances show that serious harm was substantially certain to result.
The court determined that a vehicle is an inherently dangerous instrument and that Havemeier made a conscious choice to accelerate and swerve it toward an unprotected pedestrian after a verbal confrontation. The court rejected the argument that the incident was merely impulsive horseplay or a game of chicken. It concluded that even if Havemeier meant only to scare Gatzlaff, the extreme and dangerous conduct permitted an inference of intent to injure as a matter of law.
Disposition
The court held that the policy’s intentional-injury exclusion applied. It ordered that State Farm had no duty to defend or indemnify Tyler Havemeier for the injuries resulting from the incident. It also directed State Farm, consistent with its pretrial representation, to file a notice of dismissal concerning Havemeier and Nikki Blank by September 27, 2021.
Read the full 17-page opinion on CourtListener, the free public archive maintained by the Free Law Project.