Starr Indemnity & Liability Company v. Chart Industries, Inc.

Summary

The United States District Court for the Northern District of California granted Chart Industries, Inc.’s motion to dismiss Starr Indemnity & Liability Company’s declaratory judgment action concerning Starr’s alleged duty to indemnify Chart in litigation arising from the Pacific Fertility Center freezer failure. The court held that Starr’s complaint did not establish a ripe, justiciable controversy because liability and damages in the underlying litigation had not been determined. The dismissal was without prejudice, with leave to amend within 21 days.

Holdings

1. The complaint did not allege facts establishing a ripe Article III case or controversy concerning Starr's duty to indemnify because liability and damages in the underlying litigation had not been determined and the complaint did not identify allegations showing that Starr's policy would be implicated.
2. Because Chart's challenge was treated as a facial attack under Rule 12(b)(1), the court was required to evaluate jurisdiction from the complaint's allegations rather than outside evidence.

Questions Presented

1. Whether Starr's declaratory-judgment claim concerning its duty to indemnify Chart was ripe under Article III while the underlying Pacific Fertility Center litigation remained unresolved.
2. Whether the complaint adequately alleged a concrete and actual or imminent injury sufficient to establish subject-matter jurisdiction.
3. Whether the court should dismiss, stay, or transfer the action.

Disposition

dismissed