Sellers v. Nationwide Mutual Fire Insurance Company et al

Tony Sellers was injured in a motor vehicle accident with an uninsured driver and sought uninsured motorist benefits from his insurer, Nationwide Mutual Fire Insurance Company. Nationwide denied the claim as untimely, asserting that the two-year contractual statute of limitations had expired. Sellers filed a lawsuit in the United States District Court for the Northern District of Alabama, contending that the limitations period should be tolled and that Nationwide had a duty to inform him of the deadline. The district court granted summary judgment in favor of Nationwide. On March 6, 2018, the United States Court of Appeals for the Eleventh Circuit affirmed in a per curiam decision, holding that under Alabama law the claim was time-barred and no equitable tolling applied.

The United States Court of Appeals for the Eleventh Circuit affirmed the district court's grant of summary judgment in favor of Nationwide Mutual Fire Insurance Company, holding that the suit was time-barred.

Whether the insured's claim for uninsured motorist benefits was barred by the contractual statute of limitations, and whether the insurer had an affirmative duty to notify the insured of the limitation period.

The case reinforced the strict enforcement of contractual limitation periods in Alabama insurance disputes and underscored the principle that insureds bear the burden of pursuing claims in a timely manner, without relying on the insurer to provide notice of impending deadlines.