James River Insurance Company v. Rapid Funding, LLC

658 F.3d 1207 (2011)

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James River Insurance Company v. Rapid Funding, LLC

United States Court of Appeals for the Tenth Circuit
658 F.3d 1207 (2011)

  • Written by Rose VanHofwegen, JD
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Facts

Rapid Funding, LLC (plaintiff) owned a dilapidated apartment building destroyed by fire. When it submitted an insurance claim to its carrier, James River Insurance Company (defendant), for the full $3 million of coverage, the insurer denied it, claiming that before the fire the building was worth less than $0. Rapid Funding sued the insurer in federal court and used its principal, Andrew Miller, to testify about the building’s value. The trial court allowed Mr. Miller to testify as a lay witness, not as an expert. Mr. Miller gave his opinion based on cost estimates to renovate versus reconstruct each apartment, adjusted for depreciation, and a report prepared by Anderson Group, an outside expert. The trial court awarded Rapid Funding over $5 million and the insurer appealed. The insurer argued the court erred in admitting Miller’s testimony because (1) it did not qualify as helpful lay-opinion testimony admissible under Federal Rule of Evidence 701(b); and (2) it was Rule 702 expert testimony.

Rule of Law

Issue

Holding and Reasoning (Matheson, J.)

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