Parol Evidence is not Necessary to Determine Meaning of Unambiguous Employment Contracts
In West Bend Mutual Ins. Company v. Talton, Maurice Talton (“Talton”), Robert Lash (“Lash”) and Jaa Valentine (“Valentine”) signed individual contracts to play football for the Rock River Raptors (“Raptors”) indoor football team for the 2009 season. The Raptors were part of the Continental Indoor Football League (“CIFL”), which played its home games in Rockford, Illinois. On March 7 and 20, and April 11, 2009, Talton, Lash, and Valentine, respectively, were injured while playing home games in Rockford. In June 2009, Talton filed applications for benefits with the Illinois Workers’ Compensation Commission. The injuries were reported to West Bend and coverage was sought under a policy issued to Championship Investments, LLC (“Champion”). When Talton’s and Lash’s claims were reported to West Bend, West Bend was advised that Talton and Lash were employed by Championship and that Championship owned both the Raptors and the Wisconsin Wolfpack, an outdoor football team that was a member of the North American Football League (NAFL). West Bend began paying Talton and Lash workers’ compensation benefits. West Bend did not pay Valentine workers’ compensation benefits because shortly after his injury was reported to West Bend, it was advised that Championship did not own the Raptors and that Talton’s injuries had occurred in Illinois. As a result, West Bend also stopped paying benefits to Talton and Lash. The headings on Valentine’s and Lash’s contracts state, “Championship Investments, LLC-CIFL Employment Agreement.” The heading on Talton’s agreement states, “Championship Sports-CIFL Employment Agreement.”
West Bend filed a declaratory judgment action against Talton, Championship, the Raptors and the Raptors Football Owners Club, LP. West Bend sought declaration that its policy issued to Championship did not provide coverage for Talton’s workers’ compensation claim for injuries suffered as a player for the Raptors. West Bend was not obligated to defend Championship, the Raptors, or the Raptors Football Owners Club, LP, in any Illinois Workers’ Compensation Commission proceeding; and West Bend was not obligated to indemnify Championship, the Raptors, or the Raptors Football Owners Club, LP, for Talton’s workers’ compensation claims.
The court addressed the question of whether Talton, Lash, and Valentine were employees of Championship and thereby were covered under its workers’ compensation insurance. The court looked at the words of the employment contract. Here, although the words “Championship Investments, LLC-CIFL Employment Agreement” (on Valentine’s and Lash’s contracts) or “Championship Sports-CIFL Employment Agreement” (on Talton’s contract) appear on the first page of each of defendants’ contracts, the contracts clearly and unambiguously define the parties and their relationships. The contracts define Talton, Lash, and Valentine, individually, as “Employee” and the Raptors as “Team.” Further, the contracts provide that the “Team employs Employee.” Championship is not identified as a party, either as an employer or as “Team.” Thus, the plain and unambiguous terms of the contracts provide that Talton, Lash, and Valentine were employed only by the Raptors, and nothing in the contracts indicates that they were employed by Championship. The labels typed at the tops of the first pages of the contracts do not render the clear, plain, and ordinary language of the contracts ambiguous. Accordingly, no facial ambiguity exists regarding whether Championship employed defendants; thus, parol evidence need not be considered. Thus, there is no genuine issue of material fact regarding whether Championship was Talton, Lash, and Valentine’s employer. The court did not consider extrinsic or parol evidence which Talton, Lash, and Valentine rely upon because the court would come to the same conclusion that there is no genuine issue of material fact regarding whether Championship was defendants’ employer. The record did not indicate that there was no employer-employee relationship between Championship and Talton, Lash, and Valentine. Thus, West Bend was not obligated to provide coverage for Talton, Lash, and Valentine under the terms of the policy that required coverage.
The court held that the insurer was not obligated to provide coverage for injuries the claimants sustained as players on the football team, and it was not necessary to consider parol evidence to determine the meaning of the player’s facially unambiguous employment contracts.
West Bend Mutual Ins. Company v. Talton., 2013 WL 5437049 (Ill.App. 2 Dist. 2013). (This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1).)
