Utica Mutual Insurance Company v. Fireman's Fund Insurance Company
MEMORANDUM-DECISION AND ORDER denying Deft's 442 Motion for Judgment as a Matter of Law; denying Deft's 444 Motion to correct the interest calculation in the judgment. Signed by Judge David N. Hurd on 2/28/18. (sfp, )
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
-------------------------------UTICA MUTUAL INSURANCE COMPANY,
FIREMAN'S FUND INSURANCE COMPANY,
SIDLEY AUSTIN LLP
Attorneys for Plaintiff
One South Dearborn Street
Chicago, IL 60603
WILLIAM M. SNEED, ESQ.
THOMAS D. CUNNINGHAM, ESQ.
DANIEL R. THIES, ESQ.
WILLIAMS LOPATTO PLLC
Attorneys for Defendant
1707 L Street NW
Washington, DC 20036
JOHN B. WILLIAMS, ESQ.
MARY A. LOPATTO, ESQ.
DAVID N. HURD
United States District Judge
MEMORANDUM-DECISION and ORDER
A jury trial was held between November 27, 2017, and December 13, 2017, at the
conclusion of which the jury returned a verdict in favor of plaintiff Utica Mutual Insurance
Company ("Utica" or "plaintiff") on its sole claim for breach of contract.1 The jury awarded
plaintiff $35 million in damages plus interest running from September 22, 2008. Prejudgment
interest was calculated at $29,092,191.78 and judgment entered in favor of Utica for
Defendant Fireman's Fund Insurance Company ("FFIC" or "defendant") now renews
its motion for judgment as a matter of law pursuant to Rule 50 of the Federal Rules of Civil
Procedure ("Rule __") or, in the alternative, for a new trial pursuant to Rule 59. FFIC also
separately moves to correct the interest calculation in the judgment pursuant to Rule 60. The
motions were fully briefed and have been considered on the basis of the submissions.
II. RELEVANT BACKGROUND
The parties' familiarity with the underlying facts established at trial is assumed.2 This
case has a lengthy history which all are familiar with, including years of discovery, multiple
rounds of motion practice, and a jury trial spanning nearly three weeks.
III. LEGAL STANDARDS
A. Rules 50 and 59
Rule 50(a)(1) permits a court to render judgment as a matter of law and vacate a jury's
verdict if it finds that "a reasonable jury would not have a legally sufficient evidentiary basis"
to reach its conclusion. The standard is well settled:
Judgment as a matter of law may not properly be granted under
Rule 50 unless the evidence, viewed in the light most favorable to
The verdict was rendered on December 13, 2017 and the jury was dismissed. Proceedings
continued through December 14, 2017, when defendant's counterclaims seeking rescission were dismissed
as a matter of law.
The official transcript is not yet ready, but the parties are both in possession of an unofficial
the opposing party, is insufficient to permit a reasonable juror to
find in [its] favor. In deciding such a motion, the court must give
deference to all credibility determinations and reasonable
inferences of the jury, and it may not itself weigh the credibility of
witnesses or consider the weight of the evidence.
Galdieri–Ambrosini v. Nat'l Realty & Dev. Corp., 136 F.3d 276, 289 (2d Cir.1998) (internal
The standard for post-verdict judgment as a matter of law is the same as that for
summary judgment under Rule 56. Nadel v. Isaksson, 321 F.3d 266, 272 (2d Cir. 2003).
Thus, "a district court must deny a motion for judgment as a matter of law unless . . . there
can be but one conclusion as to the verdict that reasonable persons could have reached."
Id. (internal quotations omitted). The proponent of a motion for judgment as a matter of law
under Rule 50(b) faces a "high bar," Lavin-McEleney v. Marist College, 239 F.3d 476, 479
(2d Cir. 2001), and the Second Circuit has cautioned that m otions for judgment as a matter
of law "should be granted cautiously and sparingly," Meloff v. N.Y. Life Ins. Co., 240 F.3d
138, 145 (2d Cir. 2001).
The moving party must also fulfill the procedural prerequisite of moving for judgment
as a matter of law before the case is submitted to the jury. See Fed. R. Civ. P. 50(a)(2). And
a party may only make a post-judgment Rule 50(b) motion based on grounds specifically
raised at the close of evidence. Lambert v. Genesee Hosp., 10 F.3d 46, 53-54 (2d Cir.
1993). If the movant does not meet the Rule 50 specificity requirement, the court may not
grant judgment as a matter of law unless the result is required "to prevent manifest injustice."
Lore v. City of Syracuse, 670 F.3d 127, 153 (2d Cir. 2012). A " manifest injustice" exists only
when "a jury's verdict is wholly without legal support." Jacques v. DiMarzio, Inc., 386 F.3d
192, 199 (2d Cir. 2004) (superseded by statute on other grounds).
The standard under Rule 59, which permits a court to "grant a new trial on all or some
of the issues," see Fed. R. Civ. P. 59(a)(1), is less stringent, Manley v. AmBase Corp., 337
F.3d 237, 244 (2d Cir. 2003). "[I]n deciding a motion for a new trial, the district court is
permitted to examine the evidence through its own eyes . . . [and] can grant such a motion
even if there is substantial evidence supporting the jury's verdict." Green v. City of New York,
359 F. App'x 197, 199 (2d Cir. 2009) (summary order) (internal quotations and citations
Nevertheless, "'[a] motion for a new trial ordinarily should not be granted unless the
trial court is convinced that the jury has reached a seriously erroneous result or that the
verdict is a miscarriage of justice.'" Townsend v. Benjamin Enters., Inc., 679 F.3d 41, 51 (2d
Cir. 2012) (quoting Medforms, Inc. v. Healthcare Mgmt. Sols., Inc., 290 F.3d 98, 106 (2d Cir.
2002)). Though a trial judge is free to weigh the evidence himself, the court should only
grant a Rule 59 motion when the jury's verdict is "egregious" and "should rarely disturb a
jury's evaluation of a witness's credibility." Ferreira v. City of Binghamton, No. 3:13-CV-107,
2017 WL 4286626, at *2 (N.D.N.Y. Sept. 27, 2017) (McAvoy, S.J.) (internal quotations
B. Rule 60
Rule 60(a) provides in relevant part: "(a) Corrections Based on Clerical Mistakes;
Oversights and Omissions. The court may correct a clerical mistake or a mistake arising
from oversight or omission whenever one is found in a judgment, order, or other part of the
record." Prejudgment interest is frequently the subject of Rule 60(a) motions in this Circuit.
See Roberts v. Bennaceur, 658 F. App'x 611, 621 n.9 (2d Cir. 2016) (summary order). "[A]
Rule 60(a) motion is appropriate where the judgment has failed accurately to reflect the
actual decision of the decision maker." Robert Lewis Rosen Assocs., Ltd. v. Webb, 473 F.3d
498, 504 (2d Cir. 2007) (internal quotations omitted).
A. Motion under Rule 50
FFIC renews its motion for judgment as a matter of law pursuant to Rule 50(b). It
argues it is entitled to judgment as a matter of law under Rule 50 both because Utica failed to
present legally sufficient proof that there was a breach of contract and because FFIC proved
its late notice defense as a matter of law.
Defendant raises three bases on which it claims the evidence was lacking and
consequently require the granting of its Rule 50 motion for judgment as a matter of law.
First, FFIC argues that the reinsurance certificates do not cover the loss at issue. Second,
the follow the settlements doctrine does not apply. Third, notice was late and FFIC was
economically prejudiced or Utica's failure to implement routine procedures constituted gross
negligence or recklessness.
Utica opposes and contends the presence or absence of aggregate limits in the
primary policies and the therefore subsequent question of whether the reinsurance
certificates cover the loss at issue is irrelevant to the instant inquiry and it was not required to
prove such at trial. Instead, the evidence was sufficient for a jury to conclude that its
settlement decisions were objectively reasonable and that FFIC failed to meet its burden on
its late notice defense.
Plaintiff is correct in that it was not required to prove by a preponderance of the
evidence that the primary policies contained aggregate limits for bodily injury in order for the
follow the settlements clause to apply and obligate FFIC to pay under the reinsurance
certificates. Instead, the follow the settlements clause applied unless FFIC could show that
Utica's settlement decisions were objectively unreasonable. The jury was instructed to
decide whether Utica's decision to settle with Goulds on the basis that its 1966 through 1972
primary policies contained aggregate limits was among the objectively reasonable options
available to Utica. Therefore, FFIC's continued claim that there was no coverage in the first
place—that the primary policies either lacked aggregate limits and thus did not trigger the
umbrella policies whatsoever, or in the alternative, that if the primary policies included such
limits, the reinsurance certificates did not provide coverage based on the umbrella
declarations—will not be entertained here.
1. Follow the Settlements
The jury was asked the following question regarding the first element of Utica's breach
of contract claim: "Did plaintiff Utica Mutual Insurance Company prove by a preponderance
of the evidence that it did what it was obligated to do under the 1966 through 1972
reinsurance certificates?" Although there was not a specific jury question asking such, by
answering in the affirmative that Utica did what it was obligated to do under those policies,
the jury made an implicit finding that Utica's settlement decisions regarding the Goulds
settlement were objectively reasonable, or stated another way, that FFIC did not prove that
Utica's settlement decisions were objectively unreasonable. Accordingly, the follow the
settlements provision would apply.
The jury then went on to address and answer in the affirmative that defendant failed to
do what it was required to do under the policies and thus breached the contracts and caused
damage to plaintiff. Accordingly, the inquiry under Rule 50(b) now is whether there was
sufficient evidence for a reasonable jury to conclude that Utica's settlement decisions were
objectively reasonable, the finding which resulted in FFIC's obligation to follow the
Utica presented extensive evidence that its settlement decisions were reasonable, and
while FFIC also presented extensive evidence refuting that position, it cannot be said that a
reasonable jury did not have a legally sufficient evidentiary basis on which to render a verdict
for plaintiff. Defendant cannot meet the high standard required to set aside the jury verdict
under Rule 50.
It is noted at the outset that neither party had a witness with personal knowledge of
the primary policies. Plaintiff presented the following evidence in support of its position that
its settlement with Goulds was objectively reasonable. First, Utica General Counsel Bernard
Turi testified that Utica engaged in a "full blown effort" to try to find copies of the missing
1966 to 1972 primary policies: Utica extensively searched its own records, gathered records
from Goulds, spoke with the brokers that placed the coverage, examined comparable polices
and insurance certificates, and retained outside counsel to determ ine the terms and scope of
the missing policies.
California coverage counsel for Utica, Ron Robinson, testified about the "virtual policy
project" he completed in order to reconstruct the missing policies. The "virtual policy project"
was based upon state filings, underwriting drafts, certificates of insurance, and other
secondary evidence respecting the missing policies. Plaintiff presented evidence that
Goulds' summaries of its own insurance program from the 1966 to 1972 period showed
aggregate limits for products liability. Two of the primary policies from that time period
showed an aggregate limit. Utica argued that in the absence of evidence that Goulds
intended to change its insurance program, this "book end" proof provided evidence to Utica
that the intervening policies had the same limits.
Further, Kristen Martin, the Utica attorney with day-to-day responsibility for the
underlying Goulds litigation testified that the gathered evidence clearly established that the
missing primary polices contained aggregate limits and that Utica never wavered from that
position. In sum, the results of Utica's investigation, Mr. Robinson's virtual policy project, and
the final advice from Utica's outside counsel all confirmed to Utica that the 1966 to 1972
primary polices contained aggregate limits. Dennis Connolly, one of plaintiff's experts,
opined that aggregate limits were standard in the 1960s and 70s and conf irmed the
reasonableness of Utica's position on same. Plaintiff also introduced evidence that Brian
Gagan, one of FFIC's prior experts in the underlying litigation, agreed with that position.
Considering this and other evidence together, a reasonable jury could have concluded
that Utica had a sufficient basis on which to reach the conclusion that the Goulds prim ary
polices contained aggregate limits and thus make the settlement decisions that it did.
Further in support of the jury's verdict was testimony and documentary evidence from Utica
witnesses that the settlement itself was the result of arms-length negotiations: the settlement
negotiations began in 2004, two years before the final settlement agreement; Utica and
Goulds held lengthy mediation discussions; in a stipulated order, the overseeing judges
found that the settlement was "fair, just and reasonable" and had been "entered at arms
length and in good faith by the parties."
In sum, the jury had ample evidence from which it could conclude that Utica acted
objectively reasonable in its decision to settle with Goulds for $325 million on the basis that
the primary policies contained aggregate limits for bodily injury. Therefore, there was
sufficient evidence to conclude that the follow the settlements doctrine applied and FFIC was
obligated to pay under the reinsurance certificates.
While FFIC also put forth ample evidence refuting Utica's contention that it acted
reasonably, the evidence was not such that there could have been only a verdict in
defendant's favor. Regarding the umbrella declarations which FFIC relied heavily on to
support the position that the primary policies lacked aggregate limits and thus Utica was not
reasonable in settling on the basis that there were such limits, the pages themselves nor the
testimony supporting this position required the jury to find that Utica's determination of the
primary policy terms was unreasonable. Even if the jury interpreted the umbrella policies as
evidence that the primary policies lacked aggregate limits, that evidence did not automatically
render Utica's evidence insufficient to permit a reasonable juror to find in Utica's favor,
particularly when now considering the evidence in the light most favorable to Utica, the
opposing party on the instant motion.
For example, the jury was free to credit Utica witnesses Ms. Martin and Michael
Schultz's position that they would not rely on the schedule of underlying insurance in an
umbrella policy as a definitive source of the primary policy's terms. Further, there was
nothing in the umbrella policies themselves which required that the primary policy aggregate
limits be set forth on the declarations page of the umbrella policies. Mr. Turi testified that the
declarations pages listed only the limits for basic general liability coverage, not the limits
applicable to the separate products coverage.
Finally, with respect to the reinsurance considerations, as explained in the prior
summary judgment ruling, the fact that a particular settlement decision may have reinsurance
implications does not alone render the decision improper. In fact, caselaw supports the
position that the cedent is permitted to choose the allocation most favorable to it when faced
with multiple reasonable allocations. See U.S. Fidelity & Guar. Co. v. Am. Re-Ins. Co., 20
N.Y.3d 407, 421 (2013). In any event, Ms. Martin testified that she would not have done
anything differently even if there were no reinsurance coverage, and Utica's position has
remained that it was unaware of the FFIC reinsurance at the time it settled with Goulds.
There was sufficient evidence from which a jury could conclude that Utica's knowledge of
reinsurance did not render its settlement unreasonable.
For the foregoing reasons, a reasonable jury could have concluded that Utica's
settlement decisions were objectively reasonable and thus the follow the settlements doctrine
applied. It cannot be said that a reasonable jury would not have a legally sufficient
evidentiary basis to reach a verdict for plaintiff. FFIC's Rule 50 motion for judgment as a
matter of law on this basis will be denied.
2. Late Notice Defense
The jury was asked the following question regarding FFIC's late notice defense: "Did
Fireman's Fund Insurance Company prove by a preponderance of the evidence that it
received late notice from Utica Mutual Insurance Company and that such late notice either
materially breached the reinsurance certificates or caused it demonstrable prejudice?" To
have prevailed on this defense, FFIC must have proven both late notice and either material
breach or demonstrable prejudice. A reasonable jury could have found that FFIC failed to
carry its burden; a jury could have found that FFIC failed to show demonstrable prejudice and
that it failed to show material breach. Because there was sufficient evidence for a jury to
conclude FFIC failed to prove either, there is no need to consider the late n otice prong.
- 10 -
Without a finding of demonstrable prejudice or material breach, FFIC could not sustain its
burden on its late notice defense.
The jury was instructed that FFIC must demonstrate actual prejudice, not merely
speculative or hypothetical prejudice. Prejudice is tangible economic injury and
demonstrable prejudice means that specific, tangible economic injury is shown to have
resulted from the late notice, as opposed to a claim of speculative or hypothetical injury.
FFIC argued it suffered tangible economic injury from the late notice in the form of lost
A reasonable jury could have concluded that FFIC failed to carry its burden to prove
tangible economic injury. FFIC presented no witness involved in any of FFIC's actual
negotiations with its commuting reinsurers. FFIC employee Jeffrey Svestka testified
regarding FFIC's commutation prejudice chart, which was a summary of FFIC's alleged
A reasonable jury could have afforded Mr. Svestka's testimony little or no weight.
From his testimony, Utica attorneys submitted that he did not take into account the f ollowing:
any affirmative defenses that FFIC was asserting to the billing; the amount of losses that
Utica had paid as of 1996 or any other time; any objections to payment by FFIC's reinsurers;
the fact that 5 of the 13 reinsurers were insolvent at the time of their commutations; and
whether notice was in fact due in 1996. By contrast, plaintiff put forth evidence that as of
1996 it had paid only about $100,000 over the past 10 years and, at the same rate, it would
have taken over 10,000 years to reach FFIC's reinsurance layer. Considering this testimony,
a jury could have found Mr. Svestka's assumption that FFIC was faced with a full limits loss
in 1996 not credible.
- 11 -
A reasonable jury could have also rejected FFIC's position that it would have factored
the Goulds claims into its commutation negotiations if it had received earlier notice. Mr.
Svestka testified that in 8 of the 13 commutations, FFIC attributed zero dollars in liability for
commutation of the $90 million in limits that FFIC had written as a direct insurer of Goulds.
While FFIC disputes the applicability of that evidence, a jury could have found that there was
no reason to believe FFIC would have treated the Utica reinsurance claim any differently
than a direct insurance claim. Further, Utica evidence showed that even after FFIC received
formal notice of the Utica (Goulds) reinsurance claim in July 2008, FFIC failed to take it into
account in two subsequent commutations. Considering this evidence, a reasonable jury
could have concluded that FFIC failed to show that it suffered tangible economic injury from
any late notice.
Moreover, a jury could have also found that defendant failed to show that plaintiff
acted with gross negligence or recklessness in providing notice. The jury was instructed that
to find that Utica's failure to implement routine practices and controls to ensure notif ication to
its reinsurers such as FFIC constitutes gross negligence or recklessness, the jury must find
that Utica willfully disregarded the risk to its reinsurers by doing so. FFIC had to show more
than an inadvertent lapse in routine notification procedures or even mere negligence.
Instead, it had to show a failure to implement such procedures such that Utica willfully
disregarded the risk to reinsurers and is guilty of gross negligence.
Utica employees testified that in the 1980s, Utica used a daily report and a monthly
report to inform a search for applicable reinsurance and to report such claims to reinsurers.
Mr. Turi testified that Utica's policy was to follow the notice provisions in the relevant
reinsurance contracts and that he would circulate memos and meet with the attorneys who
- 12 -
were handling claims to ensure that timely notice to reinsurers was a priority. Utica witness
Paul Thomson testified that such a procedure is what one would expect to see within a
company. Former Utica Director of Financial Reporting Daniel O'Connell testified regarding
Utica's reinsurer reporting processes, explaining the processes were manual but effective.
By contrast, the bulk of FFIC's evidence centered around Utica's specific document
retention policies and the fact that the primary policies were never located. Utica's document
retention policy was 11 years, which met the industry standard. Testimony established that
missing or incomplete contract files from the 1960s and 1970s was not out of the ordinary for
insurers dealing with these types of liability claims in the 1990s and 2000s. Utica put forth
evidence that with respect to Goulds itself, three of its five direct insurers lacked complete
contract files when coverage was being litigated.
Plaintiff also put forth evidence that it provided early notice to over a dozen facultative
reinsurers that Utica was aware of before notice was due. This evidence considered
together formed a sufficient basis for a jury to conclude that Utica had implemented routine
practices and controls to ensure notification to reinsurers which worked in the majority of
cases, and to the extent those practices did not work in the FFIC matter, such failure did not
constitute bad faith, gross negligence, or recklessness.
For all of the foregoing reasons, a reasonable jury could have concluded that FFIC
failed to sustain its burden to prove its late notice defense. Accordingly, FFIC's Rule 50
motion for judgment as a matter of law on this basis will be denied.
3. Proof of Loss
With respect to FFIC's final contention that Utica failed, as a matter of law, to establish
that its claim accrued on September 22, 2008, any such argument is waived because FFIC
- 13 -
did not raise the proof of loss issue in its Rule 50(a) trial motion. However, the proof of loss
issue will be considered under the Rule 59 standard f or a new trial.
B. Alternative Motion under Rule 59
FFIC moves in the alternative for a new trial under Rule 59 on the same grounds as its
Rule 50 motion. Even considering the evidence under the less stringent standard of Rule 59,
FFIC has failed to meet its burden to be granted a new trial for the same reasons considered
under Rule 50. The jury's decision here, as it does in most cases, turned on a question of
whose story and whose witnesses to believe and whose evidence was more compelling,
Utica's or FFIC's. The jury apparently assigned more weight to Utica's witnesses or evidence
and it cannot be said that the jury's conclusions on the follow the settlements or the late
notice defense were either seriously erroneous or a miscarriage of justice. Considering the
admissible evidence, the jury's verdict was not egregious or against the weight of the
evidence. The jury's evaluations in resolving the credibility of witnesses and other fact
finding duties will not be disturbed in this case.
As for the additional argument that the evidence was insufficient regarding the proof of
loss issue, FFIC has not shown that, based on the evidence adduced at trial, the verdict is
against the weight of the evidence, seriously erroneous, or a miscarriage of justice. The jury
was instructed that under the reinsurance certificates, FFIC was obligated to pay "promptly
following receipt of proof of loss." A proof of loss is any document or documents which
provide sufficient information for the reinsurer to intelligently form some estimate of its rights
and liabilities, and it need not contain detailed inf ormation. See SR Int'l Bus. Ins. Co. v.
World Trade Ctr. Properties, LLC, 381 F. Supp. 2d 250, 259-60 (S.D.N.Y . 2005).
- 14 -
The record contained sufficient evidence to allow the jury to determine that Utica
provided a sufficient proof of loss as of September 22, 2008, when it delivered a claims
narrative and billings to FFIC. FFIC employee Gary Ibello testified that the materials Utica
sent on September 22, 2008 were a standard format in the industry for a proof of loss.
Plaintiff also put forth evidence that FFIC had direct knowledge of the details of the Goulds
asbestos claims because it insured Goulds directly and was involved in the same Goulds
coverage lawsuit as plaintiff. Based on Mr. Ibello's and Christy Bresson's (the FFIC
employee who handled the Utica reinsurance claim) testimony, the jury could have
concluded that FFIC had sufficient information as of September 22, 2008, intelligently to form
some estimate of its rights and liabilities. The verdict was thus not against the weight of the
Therefore, FFIC's alternative Rule 59 motion for a new trial will be denied.
C. Motion under Rule 60
FFIC also moves to correct the judgment under Rule 60(a) and requests correction of
a manifest clerical error in the calculation of interest reflected in the judgment. Specifically, it
contends the interest should be reduced f rom the current $29,092,191.78 to $27,637,815
based on New York Civil Practice Law and Rule section 5001.
Defendant asserts that the error resulted from the incorrect assumption that the entire
amount owed under the reinsurance certificates ($35 million) became payable on September
22, 2008, the date of Utica's initial billing. Instead, plaintiff's initial bill was only for
$16,794,738.15, and it sent six additional billings to FFIC over the following 21 months for
the remaining balance of the $35 million. Therefore, because Utica issued its billings over
time and did not bill the entire amount on September 22, 2008, defendant contends interest
- 15 -
began to accrue only from the date of each subsequent billing. FFIC argues that under New
York law, prejudgment interest runs from the date of breach, and it could not have breached
until performance was due, i.e., the date each demand for payment was made. It contends
that such a recalculation is merely a mathematical and clerical one.
The motion is procedurally improper because such a revision would be substantive
rather than clerical and is thus not the sort of recalculation appropriate under Rule 60(a). A
revision to the interest calculation here would require a finding of fact regarding the
(additional) dates from which the interest would run. Those facts are properly ones for a jury
to decide, and they did so when they chose September 22, 2008 as the date Utica provided
sufficient proof of loss.
Accordingly, FFIC's motion to correct the interest calculation in the judgment pursuant
to Rule 60 will be denied.
For all of the foregoing reasons, defendant's renewed motion for judgment as a matter
of law or for a new trial will in all respects be denied. Defendant's motion to correct the
interest reflected in the judgment will also be denied.
Therefore, it is
1. Defendant Fireman's Fund Insurance Company's motion for judgment as a matter
of law pursuant to Fed. R. Civ. P. 50 or, in the alternative, for a new trial pursuant to Fed. R.
Civ. P. 59 is DENIED; and
2. Defendant Fireman's Fund Insurance Company's motion to correct the interest
calculation in the judgment pursuant to Fed. R. Civ. P. 60 is DENIED.
- 16 -
IT IS SO ORDERED.
Dated: February 28, 2018
Utica, New York.
- 17 -
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?