Andrew Crisman and Renee Crisman v. Chicago Title Insurance Company

Summary

The United States District Court for the District of Minnesota denied Chicago Title Insurance Company’s motion for summary judgment and granted Andrew and Renee Crisman’s motion for partial summary judgment. The court held that factual disputes remained regarding whether the Crismans had a legal right of access to their property as of the title policy’s effective date. Because Chicago Title did not establish that the underlying state-court litigation clearly fell outside the policy’s coverage, the court held that Chicago Title had a duty to defend the Crismans in that litigation.

Holdings

1. Chicago Title was not entitled to summary judgment because genuine disputes of material fact remained regarding whether Hornet Street or Hillman Drive provided the Crismans with a legal right of access as of October 2, 2013.
2. Chicago Title owed the Crismans a duty to defend the underlying state-court litigation because that litigation was arguably within the scope of the policy's protection, and Chicago Title failed to establish that the claim clearly fell outside coverage.

Questions Presented

1. Whether genuine disputes of material fact precluded summary judgment on whether the Crismans possessed a legal right of access to their property as of October 2, 2013.
2. Whether the underlying state-court litigation concerning access rights, ownership, and maintenance of Hornet Street was arguably within the scope of coverage under the title insurance policy, thereby triggering Chicago Title's duty to defend.
3. Whether the extent of the Crismans' damages for breach of contract could be resolved on their motion for partial summary judgment.

Disposition

other