Eleventh Circuit Court of Appeals
Shiloh Christian Center v. Aspen Specialty Insurance Company
11th Circuit Court of Appeals
3/13/23, Judge Newsom
Topics: Contract Interpretation
This is another case that doesn’t have too much impact on injury cases, but it does set out an important precedent for the interpretation of insurance contracts. Rather than summarizing the entire case, I simply quote—in its entirety—Judge Newsom’s introductory section:
This is an insurance case. Fear not, keep reading. In determining whether a pair of insurance policies cover losses resulting from “named windstorms,” we have to decide an important and (as it turns out) interesting question about the interpretation of written legal instruments: What is a court to do when all the surest proof of contracting parties’ subjective intentions and expectations flatly contradicts the surest indicators of an agreement’s objective legal meaning?
At the risk of oversimplifying, Aspen Specialty Insurance Company, a billion-dollar insurance conglomerate, has essentially all of the subjective-intent evidence on its side: The records of the contracting parties’ course of dealing, contractual negotiations, and policy applications strongly suggest that the parties intended and expected that the policies would exclude damage caused by named windstorms. But Aspen’s policyholder—Shiloh Christian Center, a small Florida church—has the text: However clear the parties’ subjective intentions or expectations, the policies do not, by their plain terms, exclude named-windstorm-related losses.
What, then? The district court found the evidence of the parties’ subjective intent overwhelming and accordingly granted summary judgment to Aspen. We hold, to the contrary, that, under Florida law—as in the law more generally—in the event of a conflict between clear text, on the one hand, and even compelling evidence of extra- textual “intent,” on the other, the latter must give way to the former Cf. CRI-Leslie, LLC v. Comm’r, 882 F.3d 1026, 1033 (11th Cir. 2018). We therefore reverse the district court’s decision and remand for further proceedings.