Interstate 10 Partners, LLC v. Berkley National Insurance Company

Summary

The United States District Court for the Middle District of Tennessee denied Berkley National Insurance Company’s motion for leave to file a motion for partial summary judgment and its alternative request to certify two questions to the Tennessee Supreme Court. The proposed issues concerned whether Tennessee’s bad-faith insurance statute provides the exclusive extra-contractual remedy and whether Tennessee’s statutory cap on punitive damages is constitutional. The court concluded that the proposed issues were not presently determinative of the case because liability and damages had not yet been established.

Holdings

1. The court may deny leave to file a partial-summary-judgment motion when the proposed motion would not promote judicial efficiency, even if the motion presents legal questions and no genuine factual dispute is apparent.
2. Certification to the Tennessee Supreme Court was properly denied because the proposed questions concerning potential damages were not, at that stage of the litigation, determinative of the cause.

Questions Presented

1. Whether the court should grant Defendant leave to file a proposed motion for partial summary judgment concerning the availability of punitive and other extra-contractual damages.
2. Whether the court should certify to the Tennessee Supreme Court questions concerning the exclusivity of Tennessee Code Annotated section 56-7-105(a) and the constitutionality of the punitive-damages cap in section 29-39-104.

Disposition

other