Gartner, Inc. v. HCC Specialty Underwriters, Inc.

Background

On March 1, 2024, the defendants in Gartner’s case against HCC moved for partial summary judgment. Summary judgment is a procedure for deciding claims without a trial when the governing rules allow it. On March 13, 2024, Aon filed a letter motion asking for an extension of time to respond to HCC’s motion. HCC opposed the request and argued that Aon lacked standing—that is, a sufficient legal interest—to oppose the motion.

Court’s Analysis

The court found that the issues in HCC’s motion directly implicated Aon. The court relied in part on HCC’s statement that Gartner’s claims in the related Aon case depended at least partly on whether the aggregate limits of the policy at issue in the HCC case were enforceable. The court also considered HCC’s statement that a ruling on the motion would be helpful for mediation and settlement.

The court rejected HCC’s argument that Aon should be barred from responding. It found that HCC had not identified binding authority requiring that result. The court distinguished decisions involving an unopposed motion, where a third party could not provide the only opposition to a claim that the party asserting it no longer wished to pursue. To the extent some cited decisions applied that reasoning even when the relevant party opposed summary judgment, the court disagreed.

Disposition

Judge Dale E. Ho granted Aon’s request. The court ordered Aon to file its response to HCC’s motion for partial summary judgment by April 19, 2024, and directed the Clerk of Court to docket the order in both cases. The opinion did not decide HCC’s partial summary-judgment motion itself.