Heacker v. Safeco Insurance Company of America
United States Court of Appeals for the Eighth Circuit
676 F.3d 724 (2012)
Jessica Wright hacked Lewis Heacker's (plaintiff) voicemail and Facebook account and made anonymous defamatory calls about him over several years, causing him to develop PTSD, alcoholism, and physical ailments. Wright had a homeowner's policy covering bodily injury and a separate umbrella policy covering personal injury from defamation or privacy violations, but the umbrella policy excluded coverage for mental abuse. Heacker sued Wright and sought to have her homeowner's policy cover his PTSD and alcoholism as "bodily injury." The district court held neither policy covered these conditions: the homeowner's policy because it covered only physical/bodily injury, and the umbrella policy because Heacker's injuries stemmed from mental abuse, which was excluded.
Whether physical illnesses that manifest from emotional injury are covered under a homeowner's insurance policy limited to bodily injury, or under an umbrella policy that excludes personal injury caused by mental abuse.