In Retiree Life Insurance Coverage Dispute, Eleventh Circuit Affirms Summary Judgment to Allstate Despite District Judge’s Ownership of Allstate Stock

Turner v. Allstate Insurance Company, No. 23-10187, 2023 WL 8667011 (11th Cir. Dec. 15, 2023) (Before: Jordan, Jill Pryor, and Branch, Circuit Judges).

In a per curiam opinion, the Eleventh Circuit affirmed the summary judgment order in favor of Allstate Insurance Company in this lawsuit challenging its decision to stop paying life insurance premiums for a group of retirees. Judge Emily Marks, the district court judge who issued the summary judgment order, had owned Allstate stock while the case was pending before her and should have recused. The parties were informed of this conflict just days before the Eleventh Circuit heard Plaintiffs’ challenge to the district court’s summary judgment order. Upon de novo review, a panel of this Court affirmed the summary judgment order. After the court issued its mandate, the retirees sought vacatur of the summary judgment order in the district court based on the district court judge’s failure to recuse. District Court Judge R. Austin Huffaker, construing the motion as a Rule 60(b)(6) motion, denied the motion to vacate and the retirees again appealed. This court affirmed the denial of the motion to vacate.

Judge Huffaker weighed several factors in deciding the retirees’ motion, including “the risk of injustice to the parties in the particular case, the risk that the denial of relief will produce injustice in other cases, and the risk of undermining the public’s confidence in the judicial process.” Because the Eleventh Circuit, upon de novo review, affirmed the grant of summary judgment, Judge Huffaker found that there was no risk of injustice to the parties in this case, no risk of injustice to future litigants, and no risk of undermining the public’s confidence in the judicial process. Essentially, the court found Judge Mark’s failure to recuse as harmless. The Eleventh Circuit found no abuse of discretion in Judge Huffaker’s denial of the Rule 60(b) motion.