Insurance coverage disputes Crossing the Atlantic With insurance - - PDF document

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Feature: Commerical and dispute resolution

Insurance coverage disputes

Crossing the Atlantic

With insurance coverage disputes on the rise, corporate policyholders need to ensure that they clearly understand the terms of their policies. Jane Harte-Lovelace, Thomas Reiter and Matthew Smith set out the main legal issues under UK and US law that a policyholder should consider when facing a potential dispute with its insurer and at the policy negotiation stage.

Global insurance policies offer a number

• f advantages to the policyholder such as

economies of scale, centralised adminis- tration and reduced risk of overlap or gaps in coverage. However, the cross-border na- ture of such policies means that, in the event of a dispute with an insurer, complex issues often arise as to the correct law and/or forum for resolving the dispute. Insurance coverage disputes are on the rise, particularly in the US and the UK (see box, The growth in insurance cover- age disputes: UK and US), and often

Commercial and dispute resolution: insurance coverage disputes

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involve a cross-border element. A cross- border dispute typically involves the poli- cyholder bringing proceedings in one ju- risdiction for an indemnity under the pol- icy and the insurer issuing parallel proceedings in another jurisdiction for a declaration that the policyholder has no entitlement to such an indemnity . The decision as to the correct law and/or forum may have a fundamental impact on a policyholder’s claim and even in some circumstances determine the outcome of the claim. For example, a claim by a poli- cyholder may be statute-barred on the grounds of limitation in one jurisdiction but not in another, or the policyholder may be deprived of an entitlement to re- cover an indemnity for punitive damages. There may be sound reasons to keep the policy silent as to the choice of law and/or jurisdiction (for instance, because of tac- tical considerations). However, it is worth global policyholders considering these is- sues carefully before the policy is issued and in the event of a potential dispute over coverage. This article sets out the main legal issues under UK (England and Wales) and US law that a policyholder should consider when faced with a potential dispute with its in-

• surer. In particular, it highlights the follow-

ing issues that should be determined:

The law governing the policy

. Choice of law considerations are particularly impor- tant in insurance coverage litigation. For example, particular terms may have differ- ent meanings depending on whether US or UK law governs the terms of the policy .

The correct forum or jurisdiction for

resolving disputes. Although the choice of law and jurisdiction are often linked, the parties may agree that the policy should be governed by , for example, Pennsylvania law but subject to the exclusive jurisdic- tion of the English courts.

Whether there is an arbitration clause

in the policy and, if so, what law is to be applied by the arbitrator in resolving the dispute. (See also box, Choice of law and forum selection: some general guidance.)

Law governing the policy

Under UK conflict of law rules the proper law of an insurance policy entered into af- ter 1 April 1991 can be determined by ref- erence to one of two statutory schemes de- pending upon where the risk covered by the policy is located:

Risks located inside the European Eco-

nomic Area (EEA). For risks located within a member state of the EEA, the applicable law of the insurance policy is determined by reference to the Financial Services and Markets Act 2000 (Law Applicable to Con- tracts of Insurance) Regulations 2001 (the FSMA Regulations). These regulations im- plement EU directives.

Risks located outside the EEA. Where

the risk covered by the policy is not situ- ated within the EEA, the issue as to the ap- plicable law of the contract of insurance is determined by reference to the Rome Con- vention 1980, which is implemented by the Contracts (Applicable Law) Act 1990. The rules for determining conflict of law issues differ depending upon which of these two statutory schemes applies. In the US, the conflict of law rules to be ap- plied typically are those of the forum, that is, the state in which the insurance cover- age proceedings take place. Insurance coverage disputes in the US are generally considered to present issues of state, as

• pposed to federal, law.

It is therefore not possible to establish any firm principles that would apply across the US, there being no established uniform conflict of law rules. However, a large number of states including, for ex- ample, New Jersey , follow the Restate- ment (Second) Conflict of Law Rules promulgated by the American Law Insti- tute (the Restatement), which sets out principles for resolving conflict of law is- sues. There are three possible scenarios in rela- tion to choice of law in an insurance pol- icy:

Where the parties provide expressly in

the policy for the choice of governing law.

Where there is no governing law clause

but a choice of a particular governing law can be implied.

There have been a number of key drivers for the growth of insurance coverage disputes in the US:

The scale of the successful asbestos and environmental con-

tamination claims against major US companies and thus their in- surers.

The relaxation of procedural and causation issues combined

with out of date and often loosely drafted policies.

The aggressive position asserted by insurers to rebut claims. The emergence of a specialist bar acting only for corporate poli-

cyholders, unconstrained by the “conflict” of also representing ma- jor insurance groups.

The pressure by shareholders on corporate management to pro-

tect the company’s assets and maximise insurance recovery.

Changing public sentiment against big business and in favour of

polluter pays in a jury based legal system. While the UK does not have jury-assessed damages there are a number of parallels to the US experience including:

Asbestos liabilities claims against not only manufacturers but also

the actuarial profession (estimated recently at GB£20 billion (about EUR29.5 billion or US$35.2 billion) over the next 30 years).

Financial services related claims, including mis-selling. Errors and omissions (E&O) claims and directors and officers

(D&O) claims against executive directors and, now, non-executive directors.

The increasingly aggressive positions being adopted by insurers

in resisting policyholder claims.

The growth in insurance coverage disputes: UK and US

Where there is no express or implied

choice of law . In some cases involving global policies there may be an express or even an implied choice of more than one governing law (see box, More than one governing law). Express choice of law The parties may include a clause in the pol- icy providing that it is to be governed by a particular system of law .

• UK. In relation to risks situated outside the

EEA, the parties are free to choose the ap- plicable law (Article 3, Rome Convention). Concerning risks situated within the EEA, the FSMA Regulations have also been in- terpreted by the English courts as allowing the parties the same unrestricted freedom to choose the governing law of the policy . If this interpretation is correct, the position would be the same under both the Conven- tion and the FSMA Regulations: an express choice of law in an insurance policy would prevail wherever the risks are located. US.In the US, the courts of those states that follow the Restatement may choose to ap- ply section 187 of the Restatement, which deals with the position where the parties have chosen a particular law . The law of the state chosen by the parties will be applied unless either (section 187(2), Restatement):

“The chosen state has no substantial re-

lationship to the parties or the transaction and there is no other reasonable basis for the parties’ choice”.

“

Application of the law of the chosen state would be contrary to a fundamental policy of a state which has a materially greater interest than the chosen state in the determination of the particular issue and whichwould be the state of the applicable law in the absence of an effective choice of law by the parties.” Implied choice of law Even if there is no expressly stated choice of law clause in an insurance policy , the par- ties may still in effect have agreed a choice of law .

• UK. The English courts will look at the

terms of the contract and the surrounding circumstances to decide whether or not the parties may have still chosen a particu- lar law in the absence of an express provi-

• sion. Both the Convention and the FSMA

Regulations require that the choice must be “demonstrated with reasonable cer- tainty by the terms of the contract or the circumstances of the case” (Article 3(1), Rome Convention; Reg 6(1), FSMA Regu- lations). In other words, there must be a “real” choice of law rather than a tenuous

• r uncertain choice.

The official commentary on the Rome Convention (the Giuliano-Lagarde Re- port) provides the following non-exhaus- tive list of examples of circumstances that may be taken into account in demonstrat- ing a “real” choice of a particular law:

The contract is in a standard form

which is known to be governed by a partic- ular system of law, such as a standard Lloyd’s policy of marine insurance.

There is a previous course of dealing

between the parties under contracts con- taining an express choice of law.

There is a choice of a particular forum. The contract refers to the laws of a par-

ticular legal system.

• US. The Restatement does not have a direct

and express equivalent to the UK concept of

Commercial and dispute resolution: insurance coverage disputes 3

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An issue that sometimes arises in the con- text of global insurance policies is whether more than one system of law applies to the

• policy. A global insurance policy will usu-

ally have a number of different insureds, of- ten subsidiaries of the principal policy- holder.

• UK. Under UK law the parties may agree that

different systems of law will apply to differ- ent parts of the policy. However, the English courts have so far been reluctant to imply a choice of different systems of law in a global insurance policy:

In American Motorists Insurance Co (Am-

ico) v Cellstar Corporation and another ([2003] Lloyd’s Rep IR 295) (see box, Choice of law issues: the Amico case), the in- surer argued that its relationship with the UK subsidiary (Cellstar UK) was subject to a dif- ferent governing law (that is, UK law) to that governing its relationship with the main poli- cyholder (Cellstar). The Court of Appeal re- jected this argument, stating, that “neither the parties nor the Rome Convention could sensibly be taken to have intended to scissor up the policy negotiated and issued in Hous- ton and to subject different aspects of it to different governing laws” (Mance LJ). It drew attention to the potential problems that could arise with such an approach, particu- larly where different countries had different principles or remedies governing matters such as non-disclosure or breach of warranty.

In CGU International Insurance Plc v

Ashleigh Szabo & Others ([2002] Lloyd’s Rep IR 196), the policyholder argued that a global liability policy was severable, there being separate contracts with each named

• insured. The court decided that the global li-

ability policy provided for a uniform contrac- tual framework and there was nothing to sug- gest that the definition of “the insured” un- der the policy was intended to have a differ- ent meaning according to the law of the country of the person claiming.

In El Dupont de Nemours & Co v IC Agnew

& Others ([1987] 2 Lloyd’s Rep 585), the Court of Appeal considered choice of law un- der a global product liability policy in two ex- cess layers comprising 16 separate policies, with Lloyd’s as the lead insurer on both lay-

• ers. The following policies were issued in

several different jurisdictions including The Netherlands, Texas, New York, Pennsylvania and Delaware. None of the policies con- tained an express choice of law clause. The insurers argued that the proper law of all

• f the following policies was not the same as

that of the lead Lloyd’s policy. The Court of Appeal rejected this argument and stated that, while a following policy could contain an express or implied choice of law different from that

• f

the lead policy, there was a prima facie inference that a following policy is gov- erned by the same law as the policy it follows. The Court of Appeal decided that there was an implied choice of UK law in the lead Lloyd’s policies and on the evidence there was no reason why the same law should not apply to the following policies.

• US. The courts in those states that follow the

Restatement (Second) Conflict of Law Rules (Restatement) may apply section 187 to de- termine the appropriate law where there has been an express choice by the parties of dif- ferent systems of law for different parts of the

• policy. The Restatement does not provide ex-

pressly for an implied choice of law by the parties (see main text, Implied choice of law: US).

More than one governing law

an “implied” choice of law . However, some commentators have suggested that section 187 of the Restatement may be wide enough to allow the courts to conclude that the par- ties have made an effective choice in the ab- sence of an express governing law clause. No choice of law

• UK. Under UK law, where there has been

no choice (express or implied) the two statutory schemes set out the principles to be applied in determining the governing law of the insurance policy:

Risks located outside the EEA.In the ab-

sence of a choice of law by the parties, the contract will “be governed by the law of the country with which it is most closely con- nected” (Article 4(1), Rome Convention). A presumption exists that the contract is closely connected with the country where the party that is to effect the performance “characteristic” of the contract has, at the time of conclusion of the contract, its ha- bitual residence or, in the case of a com- pany , its central administration (Article 4(2)). If the contract is entered into in the course of that party’s trade or profession, the appropriate country is that in which the “principal place of business” is situated. If, however, it is the case that performance of the contract is to be effected through a place

• f business other than the principal place of

business, the appropriate country is stated to be that in which the other place of busi- ness is situated. As far as a contract of insurance is con- cerned, it has been argued that the charac- teristic performance is the provision of in- surance cover. If this is correct, the party that is to effect the performance that is characteristic of the contract of insurance would be the insurer. The contract of insur- ance would therefore be presumed to be most “closely connected” either with the country in which the insurer has its princi- pal place of business or, where perform- ance is effected through a branch office, the country in which that office is situated. For example, under this view, if the New Y

• rk
• ffice of a US insurer headquartered in

Delaware issues a policy for an office build- ing in California owned by an English com- pany , the presumption under the Rome Convention would be that New Y

• rk law

will apply to the insurance policy . The pre- sumption can, however, be rebutted de- pending on the facts of a particular case.

Risks located within the EEA. The

FSMA Regulations also employ the con- cept of “close connection”. The Regula- tions again provide that the contract of in- surance will be governed by the system of law of the country with which the contract has its closest connection. However, a dif- ferent presumption is to be applied in iden- tifying the “closest connection”. There is a presumption (again rebuttable) that the contract of insurance has its closest connec- tion with the EEA state in which the risk is situated (Regulation 4, Part II, FSMA Regu- lations). To give another example, if a New Y

• rk insurer covered a factory in England,

the presumption under the FSMA Regula- tions would be that UK law would apply to

Commercial and dispute resolution: insurance coverage disputes

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One illustration of the practical application

• f the UK law principles concerning choice
• f law issues is provided by the case of Amer-

ican Motorists Insurance Co (Amico) v Cell- star Corporation and another ([2003] Lloyd’s Rep IR 295). Cellstar, a US mobile phone distributor, had taken out a global transportation policy with insurer Amico. Amico was incorporated in Illinois but autho- rised to conduct business in Texas. The named insured under the policy was “Cellstar Corporation and its Subsidiaries” and the policy covered mobile phones when “in transit in the care and custody or control

• f the carrier”. The policy was negotiated in

Houston, Texas through Texas brokers. One of the subsidiary companies of Cellstar was Cellstar UK, based in Manchester, Eng-

• land. Two shipments of mobile phones being

transported from Cellstar UK’s warehouse in Manchester went missing in transit. Amico purported to deny the resulting claim on grounds of breach of warranty and both Cell- star and Cellstar UK commenced proceed- ings in Texas against Amico. Amico re- sponded by bringing parallel proceedings in England for a declaration that it was not li- able to Cellstar and its subsidiary under the

• policy. The English court had to decide

whether the policy was governed by UK or Texan law. The first question was whether there had been a choice of law. There was no express choice of law clause in the policy and the court therefore had to decide whether a choice of law could be implied. The court addressed the issue as to whether the pol- icy and the circumstances demonstrated with reasonable certainty that the policy- holder and the insurer had made a “real choice” of a particular system of law. The Court of Appeal held that there was an im- plied choice of Texan law. In giving judg- ment, Mance LJ cited the following in sup- port of this conclusion:

The policy had been negotiated and is-

sued in Texas between an insured who em- ployed a Texas broker, and an insurer situ- ated in Texas.

The policy provided for a limitation period

• f 12 months from the date of the loss unless

such limitation was invalid “by the laws of the State within which [the policy] is is- sued”. This was believed to be a strong indi- cation that the parties had chosen the law of the state in which the policy was issued, that is, Texas law, as the governing law.

It was a group policy negotiated by the

parent company in the state where it had its principal place of business.

Neither those negotiating the policy nor

any of Cellstar’s subsidiaries could reason- ably have contemplated that the policy would be governed by more than one system

• f law.

Mance LJ considered the position if the answer to the first question was wrong and there was no choice of law. This meant considering the presumptions under the statutory provisions now replaced by the Financial Services and Markets Act 2000 (Law Applicable to Contracts of Insurance) Regulations 2001 and the Rome Conven- tion 1980. He decided that, even if there was no implied choice of law, the circum- stances and the manner in which the pol- icy was issued were sufficient to outweigh any presumption in favour of the law of the EEA state in which the risk was situated (that is, UK law). If the Rome Convention applied, Mance LJ found that the presumption would also be in favour of Texas given that performance was by Amico through its Houston office where the policy was negotiated and issued. How- ever, even if that was wrong and the pre- sumption was in favour of the state in which Amico had its central administration (as- sumed to be Illinois, where the company was registered) Mance LJ stated that this pre- sumption was again outweighed by the cir- cumstances, which all pointed to Texan law as the governing law.

Choice of law issues: the Amico case

Commercial and dispute resolution: insurance coverage disputes 5

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the contract of insurance.

• US. In those US states that follow the Re-

statement, “the rights and duties of the parties with respect to an issue in contract are determined by the local law of the state which, with respect to that issue, has the most significant relationship to the transaction and the parties” (section 188(1), Restatement). A number of factors are relevant to deter- mining the applicable law where there is no statutory directive on choice of law within the forum state (section 6, Restate- ment). These include:

The relevant policies of other poten-

tially interested states.

The relative interests of those states in

the determination of the particular issue. In addition, section 188(2) specifies a number of matters to be taken into ac- count in applying the governing principles

• f section 6 to determine the proper law

where there is no effective choice of law by the parties. These include:

The domicile, residence or nationality

• f the parties.

The place of negotiation, conclusion

and performance of the contract.

The place where the injury and the con-

duct causing it occurred.

The correct forum/jurisdiction

It is important to be aware of the funda- mental distinction between choice of law and jurisdiction. A “forum selection clause” (US) or “jurisdiction clause” (Eng- land) in an insurance policy specifies the courts before which any disputes relating to its terms should be brought. This does not necessarily need to be consistent with the chosen law . A clause might, for example, provide for the resolution of disputes by the English courts applying New Y

• rk law

.

• UK. Under UK law, jurisdiction in matters

relating to insurance where the defendant is domiciled in an EU member state is (subject to certain limited exceptions) de- cided by reference to a number of detailed provisions in Council Regulation (EC) 44/2001 of 22 December 2000 on jurisdic- tion and the recognition and enforcement

• f judgments in civil and commercial

matters (the Brussels Regulation), which supersedes the 1968 Brussels Convention. According to these provisions, persons domiciled in a member state, whatever their nationality , are to be sued in the courts of that member state (Article 2, Brussels Regulation). A corporate entity is domiciled where it has its statutory seat, central administration, or principal place

• f business. In matters relating to insur-

ance, policyholders generally have a choice of courts but insurers are restricted to the courts of the member state in which the policyholder is domiciled (Articles 8- 14, Brussels Regulation). Where the defendant is not domiciled in the EU (or Iceland, Norway and Switzer- land, which are parties to the Lugano Convention 1988) the English courts will apply common law principles, supple- mented by statute and the Civil Procedure Rules 1998, to determine whether they have jurisdiction and, if so, whether to ex- ercise that jurisdiction. In particular, the English courts have a discretion to decide whether to grant a stay of proceedings on the grounds of forum non conveniens (that is, on the basis that the courts of an-

• ther jurisdiction, such as a US jurisdic-

tion, would provide a more appropriate forum). A number of English cases over the past few years have addressed the issue as to whether, in the light of the Brussels Con- vention and the Brussels Regulation, the English courts still have the discretion to stay proceedings against defendants domiciled in England on forum non con- veniens grounds. In the recent case of Owusu v Jackson & Others ([2005] 1 Lloyd’s Rep 452) the Eu- ropean Court of Justice (ECJ) decided that where proceedings were commenced in England against a defendant domiciled in England, the English courts had no dis- cretion to stay the proceedings in favour of a more appropriate forum (in that case Bermuda). The provision in the Brussels Convention (and the provision in the Brussels Regulation which replaced it) was held to be mandatory . The ECJ de- cided that an English court cannot stay proceedings against a defendant domi- ciled in England in favour of the courts of another non-European jurisdiction even if that jurisdiction is a more appropriate fo- rum for resolving the dispute. An exclusive jurisdiction or forum selec- tion clause in the insurance policy may avoid having to deal with the fairly de- tailed provisions in the Brussels Regula- tion in any dispute over jurisdiction where the defendant is domiciled in an EU mem-

At the contract negotiation stage, global policyholders should:

Determine whether an express choice of law and/or jurisdiction

clause is, or ought to be, included in the policy and the effect on any claims under the policy. An express choice of law clause may add greater certainty to the coverage provided by the policy.

Consider agreeing a choice of law and/or jurisdiction that will

minimise the introduction of public policy concerns into any dis- pute with insurers, for instance, the UK. (Note that public policy in some US states such as New York and Illinois preclude, or may in some circumstances preclude, indemnification of an insured against an award of punitive damages. The argument is said to be that since punitive damages are awarded on grounds of personal li- ability for grossly reprehensible conduct, it is against public policy for the insured to escape punishment by seeking an indemnity from the insurer.)

Consider combining the choice of law and jurisdiction clauses

(that is, providing for the same jurisdiction as the chosen law). This may avoid the potential for disputes over the appropriate law and/or jurisdiction.

Remember that there may well be numerous insurers, possibly

domiciled in different jurisdictions, covering the various layers in the insurance programme.

Consider an arbitration clause as an alternative to a clause giv-

ing exclusive jurisdiction to the courts. The English courts and the courts in the US will generally enforce an arbitration clause.

Choice of law and forum selection: some general guidance

ber state and the opposing proceedings are commenced outside Europe. Under the Brussels Regulation, such a clause will be effective in these circumstances if it is in favour of the policyholder but can only be relied upon by the insurer if the restrictive conditions in Article 13 are met.

• US. In the US, the position again differs

between states although US courts will of- ten take a forum non conveniens ap- proach to determining issues of jurisdic-

• tion. In relation to jurisdiction or forum

selection clauses, the leading case in the US is The Bremen v Zapata Off-Shore Co (407 US 1 1972), in which the Supreme Court held that forum selection clauses are “prima facie valid and should be en- forced unless enforcement is shown by the resisting party to be ‘unreasonable’ in the circumstances”. Courts in US states will generally enforce such clauses, following the Supreme Court’s decision in The Bre- men,where it is reasonable to do so. The reasons for refusing enforcement of a forum selection clause, often described as the “unreasonableness test”, include fraud, overreaching (that is, uneven bar- gaining power), unfairness or public pol- icy grounds.

Arbitration clauses

An arbitration clause can be used in an in- surance policy as an alternative to requir- ing coverage disputes to be determined by the courts of a particular jurisdiction. The arbitration clause can be combined with a choice of law clause. Note, how- ever, that the governing law to be applied in interpreting the terms of the policy (of- ten described as the “substantive law”) will not always apply to the arbitration procedure (“procedural law”). This is be- cause the “seat” or location of the arbitra- tion may be in a different jurisdiction to that of the chosen substantive law. The seat of the arbitration typically deter- mines the procedure and, to be effective, an arbitration award has to comply with the requirements imposed by the law of the seat of the arbitration. The combination of an arbitration clause and a choice of law clause in an insurance policy may also allow the parties to agree to modify the application of the chosen substantive and/or procedural law to the dispute. An illustration of this is provided by the “Bermuda form” excess liability insur-

• ance. The Bermuda form policy requires

disputes to be resolved by arbitration in London, England, according to UK law (the procedural law) but provides for a modified version of New Y

• rk law in de-

termining disputes arising under the pol- icy (the substantive law). These modifica- tions relate to, for instance:

Punitive damages, which, it is often ar-

gued, are uninsurable under the law of the state of New Y

• rk (as well as a number of
• ther US states) on grounds of public policy

(see box, Choice of law and forum selec- tion: some general guidance). The Bermuda form policy therefore includes a provision expressly modifying the application of New Y

• rk law to enable the policyholder to

recover an indemnity for punitive damages.

The application of the UK Arbitration

Act 1996 to the arbitration procedure. The Bermuda form policy provides that the par- ties waive their rights under the Act to apply to the court for determination of any ques- tion of law arising in the proceedings (sec- tion 45) and any right of appeal to the Eng- lish courts on a point of law (section 69). In the UK and in the US, a valid arbitration agreement will generally be enforced, al- though in the US the formal requirements for the validity of such an agreement may vary . There is a long line of US cases up- holding arbitration clauses in international

• contracts. In the UK, the Brussels Regula-

tion provides that it does not apply to arbi- tration (Article 1(2)). Where the interpreta- tion of the arbitration clause is subject to UK law, it will be interpreted in accordance with the provisions of the Arbitration Act, which set out the requirements for the exis- tence of a valid arbitration clause.

Commercial and dispute resolution: insurance coverage disputes

6

Jane Harte-Lovelace is head of the insurance coverage practice of Kirkpatrick & Lockhart Nicholson Graham’s London office and Thomas M Reiter is a partner in the Pittsburgh office of the firm. Matthew E Smith is a senior associate in the London office of Kirkpatrick & Lockhart Nicholson Graham. This article can be found on

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