Minnesota Fire and Casualty Co. v. Greenfield
Pennsylvania Supreme Court
855 A.2d 854 (2004)
- Written by Rich Walter, JD
Facts
Michael J. Greenfield (plaintiff) was a heroin dealer. Pennsylvania statutes specifically listed heroin as an illegal controlled substance with no accepted medical use and a high potential for abuse. A young woman visited Greenfield at his house, bought heroin, injected the substance, passed out, and died on Greenfield’s floor. Greenfield faced criminal charges for the incident, and the woman’s parents sued Greenfield for damages. Greenfield’s insurer, Minnesota Fire and Casualty Company (insurer) (defendant), refused to defend or indemnify Greenfield against the parents’ claim. Greenfield sued to enforce his policy coverage. The trial court ruled that Greenfield was entitled to insurance coverage because he neither expected nor intended the woman’s death. An intermediate appellate court reversed, ruling that a user’s death was an expectable consequence of selling heroin to the user and that public policy precluded coverage. Greenfield appealed to the Pennsylvania Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Newman, J.)
Dissent (Cappy, C.J.)
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