Originally from:

Journal of American Arbitration (JAA) - Vol. 3, No. 2

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ARTICLES

When Can Courts Consolidate Arbitrable
Insurance Claims? The Minnesota Supreme
Court Answers in Illinois Farmers Insurance
Co. v. Glass Service Co.
By Kristin Schork

I. OVERVIEW
Glass Service Company, and its wholly-owned subsidiary Glass
Service Center (collectively, Glass Service), alleged that it had been
underpaid for glass work it performed for the policyholders of Illinois
Farmers Insurance Company and Mid-Century Insurance Company
(collectively, Farmers) between August 1997 and April 2002 in excess of
one million dollars.1 According to Minnesota’s statutory scheme, all
automobile policies must “complete coverage for repair or replacement
of all damaged safety glass without regard to any deductible or minimum
amount.”2 Thus, “[b]y forbidding deductibles, [the statute] for
automobile insurance essentially removes the auto glass customer from
the payment process. As a result, auto glass companies routinely bill
their customers’ insurance companies directly.”3 To comply with the
statute, Glass Service’s invoice states that the policyholder “assign[s] any
and all claims in connection with this installation against my insurance