Maggie J. Robinson v. Liberty Mutual Insurance Company
Unreported, 11th Cir. (May 11, 2020) (2020)
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Rule of Law:
Under Alabama law, the terms of an insurance policy are interpreted according to their ordinary, common meaning as understood by a reasonably prudent person, not their technical or scientific definition.
Facts:
- Maggie and Cody Robinson discovered an infestation of venomous brown recluse spiders in their home.
- After an initial attempt to eradicate the spiders, the Robinsons purchased a homeowners insurance policy from Liberty Mutual Insurance Company.
- The policy insured against direct physical loss to property but contained an exclusion for any loss caused by 'birds, vermin, rodents, or insects.'
- Further attempts to eradicate the severe spider infestation failed.
- The Robinsons filed a claim with Liberty Mutual for property damage, alleging the infestation made their home unsafe and uninhabitable.
- Liberty Mutual denied the claim, citing the policy's exclusion for damage caused by insects and vermin.
Procedural Posture:
- Maggie and Cody Robinson sued Liberty Mutual Insurance Company in the United States District Court for the Northern District of Alabama, a federal trial court.
- The Robinsons' complaint alleged breach of contract and bad faith refusal to pay their insurance claim.
- The district court granted Liberty Mutual's motion to dismiss the complaint for failure to state a claim upon which relief can be granted.
- The Robinsons, as plaintiffs-appellants, appealed the district court's dismissal to the United States Court of Appeals for the Eleventh Circuit.
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Issue:
Does a homeowners insurance policy exclusion for property damage caused by 'insects' or 'vermin' apply to a brown recluse spider infestation when interpreted according to the ordinary meaning of those terms?
Opinions:
Majority - William Pryor, Circuit Judge
Yes, the exclusion for 'insects' and 'vermin' applies to a brown recluse spider infestation. Under Alabama law, insurance policy terms must be given their ordinary, everyday meaning. Although spiders are scientifically classified as arachnids, numerous dictionaries demonstrate that the ordinary, popular meaning of 'insect' includes spiders. Furthermore, the Robinsons' own description of the spiders as a pervasive, harmful, and difficult-to-control infestation that rendered their home dangerous fits the common dictionary definition of 'vermin,' which includes small, noxious, or objectionable animals that infest a space. The court properly consulted dictionaries to determine these legislative facts, which are universally applicable truths about language, rather than adjudicative facts specific to this case.
Analysis:
This decision reaffirms the principle that contract language, especially in insurance policies, is interpreted from the perspective of an ordinary person, not a scientific expert. It solidifies the use of dictionaries as a primary tool for determining the common meaning of undefined policy terms. The ruling provides insurers with greater certainty that exclusions using common words will be enforced according to popular understanding, while cautioning policyholders that scientific distinctions will not override plain language. This precedent may make it more difficult for insured parties to challenge coverage denials based on technical or scientific classifications of terms that also have a broader, common meaning.
