St. Paul Fire and Marine Insurance Co., a Minnesota Corporation, Appellant (defendant), Hartford Accident And…

Summary

The Wyoming Supreme Court reversed a summary judgment that had required St. Paul Fire and Marine Insurance Co. to pay a $33,000 civil-rights judgment entered against Albany County School District No. 1. Construing the 'Board of Education Liability Policy Including School District Reimbursement' as a matter of law, the court held the policy insured only individual board members and employees and covered the district solely for amounts it was required or permitted to indemnify those individuals; because the judgment ran against the district itself and no individual was personally liable, no coverage existed. The court further held that waiver and estoppel cannot expand policy coverage beyond its terms, and declined to adopt the doctrine of reasonable expectations where the policy language is clear and unambiguous.