In State Auto Prop. & Cas. Ins. Co. v. Williams, No. 20-CV-1420, 2021 WL 2106488, at *4 (C.D. Ill. March 15, 2021), the District Judge applied a rule of federal jurisdiction which is summarized in the title of this article: No "specific, identifiable" claim or case? No federal jurisdiction.
In that case, the federal court did not have jurisdiction to issue declaratory relief as between a liability carrier and Norfolk Southern Railway Company, "a purported additional insured" under a policy the carrier issued to one Williams. Williams, in turn, was doing business as Jandi Services, a cleaning company. Norfolk contracted with Williams d/b/a Jandi Services for cleaning services. State Auto Property, 2021 WL 2106488, at *1. Although the underlying claimant provided Norfolk with an unfiled draft complaint against Norfolk, State Auto Property, 2021 WL 2106488, at *2, there was no underlying action against Williams. State Auto Property, 2021 WL 2106488, at *2.
Making a complicated story simpler, there was no "specific, identifiable" claim or case in the eyes of the District Judge. The Court accordingly granted the defendants' motion to dismiss the carrier's complaint seeking a declaration that it has no duty to defend. State Auto Property, 2021 WL 2106488, at *6.
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