Uffner v. La Reunion Francaise

On March 18, 1997, Daniel L. Uffner, Jr. (plaintiff) took out an insurance policy on his yacht. The policy was issued by La Reunion Francaise, S.A., a French marine insurer, and underwritten by T.L. Dallas & Co. Ltd., an English marine underwriter, and Schaeffer & Associates, Inc. (defendants), a Georgia-based U.S. underwriter. On June 14, 1997, Uffner’s yacht caught fire and sank near the coast of Puerto Rico. Uffner filed a claim with his insurance broker. The defendants denied Uffner’s claim on the ground that there was no “current out-of-water survey.” Uffner filed suit in the United States District Court for the District of Puerto Rico on June 12, 1998 for the bad-faith denial of an insurance claim. The defendants moved to dismiss for lack of subject matter jurisdiction, improper venue, and failure to state a claim upon which relief can be granted. The defendants did not object to personal jurisdiction. The court dismissed Uffner’s complaint without prejudice for lack of personal jurisdiction over the defendants and improper venue. In assessing venue, the court noted that Uffner’s claim was based in contract, not tort law. Because of this, the court held that the “triggering event” was the denial of the claim under the contract, which had nothing to do with the events that occurred in Puerto Rico. Uffner moved for reconsideration and leave to amend the complaint, but the court denied both motions on December 10, 1999. Uffner appealed to the United States Court of Appeals for the First Circuit.