INSURANCE-RELATED COURT CASES
Digested from case reports published online
COURT DECISIONS
A seedy deal
Almost two decades prior to this decision, the Mississippi Supreme Court handed down Farmland Mutual Insurance Co. v. Scruggs. In that opinion, the court held that Farmland, the liability insurer for Mitchell Scruggs, Eddie Scruggs, Scruggs Farms & Supplies LLC, and Scruggs Farm Joint Venture (collectively, Scruggs), had no duty to defend Scruggs in a federal lawsuit by Monsanto Company. The reason no coverage applied was that Monsanto had alleged that Scruggs committed the intentional act of conversion by saving and using unlicensed seeds.
Eight years later, in 2012, a district court judge overturned a jury’s verdict that Scruggs had willfully violated Monsanto’s patents and had no duty to defend Scruggs in a federal lawsuit by Monsanto. The reason no coverage applied was that Monsanto had alleged that Scruggs committed the intentional act of conversion by saving and using unlicensed seeds. Consequently, Scruggs was not liable for treble damages and attorney’s fees.
Scruggs returned to state court in2013. Citing Rule 60(b) of the Mississippi Rules of Civil Procedure, Scruggs asked the Lee County Circuit Court to reopen and vacate the final judgment entered in 2004 in favor of Farmland on the coverage issue.
Scruggs asserted that the Mississippi Supreme Court’s opinion had been erroneously decided based on facts that came to light in the federal case. The state court rejected the motion as untimely under Rule 60(b). Scruggs appealed.
While Scruggs asserted that the motion was timely, the Mississippi Supreme Court found that the motion’s timing was irrelevant: Rule 60(b) was not a procedural vehicle for a trial court to overturn a mandate issued from the Mississippi Supreme Court.
Because the trial court lacked jurisdiction to grant Scruggs’s request, the supreme court affirmed the circuit court’s denial of the motion.
Scruggs, et al. v. Farmland Mutual Insurance Company—Mississippi Supreme Court—March 9, 2023—No. 2021-CA-00877-SCT. n
