Erie Insurance Exchange v. Gary Rose, Individually and d/b/a American Masonry and Capital Builders, LLC
Erie Insurance Exchange appealed the Davidson County Chancery Court's dismissal of its declaratory judgment action. Erie sought a declaration that its insurance policy issued to Gary Rose excluded coverage for claims brought by Capital Builders, LLC in a separate Williamson County action and that Erie had no duty to defend Rose. The Davidson County action was dismissed based on the 'prior suit pending' doctrine because the Williamson County action involved the same parties and identical subject matter concerning Erie's obligations under the insurance policy. The Court of Appeals affirmed the dismissal, agreeing that Erie's declaratory judgment claim should be litigated within the existing Williamson County action, and found no improper prejudice regarding the introduction of insurance evidence.