Mid-American Fire & Casualty Co. v. Heasley

{¶ 1} In this case, we address two issues: (1) when an insurance company may maintain a declaratory judgment action against an insured whose claim for coverage was extinguished by Westfield Ins. Co. v. Galatis, 100 Ohio St.3d 216, 2003-Ohio-5849, 797 N.E.2d 1256, and (2) what the appropriate standard of review is for a trial court’s dismissal of such an action.

{¶ 2} We have accepted a discretionary appeal and certification of a conflict and have consolidated them. The Eleventh District Court of Appeals certified its decision concerning the justiciability of a declaratory judgment as well as…