Jadair International , Inc. v. American National Property & Casualty Company

In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 22-3053
J ADAIR INTERNATIONAL , INC.,
Plaintiff-Appellant,
v.
A MERICAN NATIONAL P ROPERTY & C ASUALTY C OMPANY ,
Defendant-Appellee.
____________________
Appeal from the United States District Court for the
Eastern District of Wisconsin.
No. 2:21-cv-1103 — J.P. Stadtmueller, Judge.
____________________
A RGUED MAY 25, 2023 — D ECIDED A UGUST 9, 2023
____________________
Before EASTERBROOK , R OVNER , and L EE , Circuit Judges.
LEE , Circuit Judge. David Schmutzler was the owner and
president of Jadair International, Inc. (“Jadair”). He was also
a pilot with decades of experience. On Jadair’s behalf,
Schmutzler secured an aircraft insurance policy from the
American National Property & Casualty Company (“Ameri-
can National”), covering a Cessna airplane owned by Jadair.
Tragically, the Cessna crashed in May 2020, killing Schmutz-
ler, who was piloting the plane. Jadair filed a claim on the

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2 No. 22-3053
policy. American National denied coverage because Schmutz-
ler did not have a current and valid medical certificate from
the Federal Aviation Administration (“FAA”) at the time of
the accident. Jadair sued American National in federal court
for payments due under the policy. The district court granted
American National’s motions for summary and declaratory
judgment, holding that the policy unambiguously excludes
coverage for any accident involving the Cessna where the pi-
lot lacks a current FAA medical certificate. We affirm.
I. BACKGROUND
A. Insurance Policy and Accident
Schmutzler applied to American National for an insurance
policy on the Cessna, FAA registration number N1JA, in 2019.
The application listed Schmutzler as the Cessna’s only author-
ized pilot.
On the application, Schmutzler indicated that he was a li-
censed pilot with an FAA medical certificate.1 Id. The applica-
tion included a section titled “Minimum Pilot Requirements,”
which stated that “there is no coverage in flight unless the air-
craft is being operated by the pilot(s) designated on this doc-
ument who has/have at least the certificates, ratings, and pilot
experience indicated, and who … is/are properly qualified for
the flight involved.” Schmutzler initialed this provision.
1 The FAA generally requires pilots to obtain medical certificates in-
dicating that they are physically fit to fly. Certificates are issued for a spec-
ified period of time, after which they expire. See Bullwinkel v. U.S. Dep’t of
Transp., 787 F.2d 254, 255 (7th Cir. 1986).

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No. 22-3053 3
American National issued the policy to Jadair on June 27,
2019. We will summarize briefly the provisions of the policy
most relevant to this case.
First, Item Nine of the policy’s Coverage Identification
Page states:
The Aircraft must be operated in flight only by
a person having the minimum qualifications
shown below. The pilot must have a current and
valid (1) medical certificate, (2) flight review
and (3) pilot certificate with necessary ratings,
each as required by the FAA for each flight.
THERE IS NO COVERAGE IF THE PILOT
DOES NOT MEET THESE REQUIREMENTS.
AS ENDORSED
This boilerplate provision is subject to the following Endorse-
ment:

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4 No. 22-3053
After the policy was bound and during the coverage pe-
riod, on May 15, 2020, the Cessna crashed, killing Schmutzler,
who was piloting the craft. It is undisputed that Schmutzler
lacked a current and valid FAA medical certificate at the time
of the accident (his previous certificate had expired). It also is
undisputed that the accident was not caused by any health
condition of Schmutzler’s. It seems that the Cessna suffered a
mechanical failure.
Jadair filed a claim on the policy. American National de-
nied it, stating that the policy excludes coverage for accidents
involving a pilot without a current and valid FAA medical
certificate.
B. Proceedings Below
Jadair sued American National in federal court, seeking a
declaratory judgment that the accident was covered under the

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No. 22-3053 5
policy. American National counterclaimed for a declaratory
judgment that the accident was not covered, and the parties
filed cross-motions for summary judgment. The district court
entered summary and declaratory judgment for American
National, holding that the policy did not cover the accident
because Schmutzler lacked a current and valid FAA medical
certificate and the policy states that such a certificate is a re-
quirement for coverage. Jadair Int’l, Inc. v. Am. Nat’l Prop. &
Cas. Co., 635 F. Supp. 3d 667, 685 (E.D. Wis. 2022).2 Jadair now
appeals.
II. DISCUSSION
Jadair raises multiple arguments on appeal. Principally, it
contends that the policy, and more specifically the Endorse-
ment, exempts Schmutzler from any medical-certificate re-
quirement and, therefore, the district court erred when it held
that Schmutzler’s failure to comply with this requirement was
a basis to deny coverage. Jadair also argues that, even if the
medical-certificate requirement applies to Schmutzler, Wis-
consin law requires American National to prove that
Schmutzler’s violation of the requirement increased American
National’s risk of loss or contributed to the accident. See Wis.
Stat. § 631.11(3). Alternatively, Jadair asks us to certify a ques-
tion to the Wisconsin Supreme Court about the scope of
§ 631.11(3) in the context of aviation insurance.
2 The district court also rejected a separate claim by Jadair that Amer-
ican National had acted in bad faith in denying coverage under the policy.
Id. at 684. Jadair raises no challenge to this holding, so we will not discuss
it further.

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6 No. 22-3053
As we are sitting in diversity, 3 we apply state substantive
law and federal procedural law to resolve these issues. Santa’s
Best Craft, LLC v. St. Paul Fire & Marine Ins. Co., 611 F.3d 339,
345 (7th Cir. 2010). With respect to the former, the parties
agree that Wisconsin substantive law governs. Jadair Int’l,
635 F. Supp. 3d at 674–75.
As to the latter, this appeal comes to us from the district
court’s grant of summary and declaratory judgment for
American National. A court “shall grant summary judgment
if the movant shows that there is no genuine dispute as to any
material fact and the movant is entitled to judgment as a mat-
ter of law.” Fed. R. Civ. P. 56(a). Material facts are facts that
“might affect the outcome of the suit,” and a dispute as to
those facts is genuine if “the evidence is such that a reasonable
jury could return a verdict for the nonmoving party.” Ander-
son v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). In determin-
ing whether a genuine dispute of material fact exists, we
“view the evidence and draw all [reasonable] inferences in a
way most favorable to the nonmoving party.” Bombard v. Fort
Wayne Newspapers, Inc., 92 F.3d 560, 562 (7th Cir. 1996).
Furthermore, the Declaratory Judgment Act permits a fed-
eral court to “declare the rights and other legal relations of
any interested party” in the case of an “actual controversy”
within the court’s jurisdiction. 28 U.S.C. § 2201(a); see also Fed.
3 Jadair is a Wisconsin corporation with its principal place of business
in Wisconsin, and American National is a Missouri corporation with its
principal place of business in Missouri. The amount in controversy ex-
ceeds $75,000. 28 U.S.C. § 1332(a). Although Jadair brought its action in
part pursuant to the federal Declaratory Judgment Act, 28 U.S.C. § 2201,
that Act does not enlarge our subject matter jurisdiction. California v. Texas,
141 S. Ct. 2104, 2115–16 (2021).

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No. 22-3053 7
R. Civ. P. 57. There is no dispute that the Act applies to this
case.
We will treat the district court’s grants of summary judg-
ment and declaratory judgment together, since the parties do
not differentiate between them, and both turn on the same
questions of law.4 We review the district court’s judgment
de novo. REXA, Inc. v. Chester, 42 F.4th 652, 662 (7th Cir. 2022);
Vanliner Ins. Co. v. Sampat, 320 F.3d 709, 711–12 (7th Cir. 2003).
With that, we turn to Jadair’s arguments.
A. Whether the Policy Covers Jadair’s Claim
To interpret insurance policies, Wisconsin courts employ
the standard rules of contract construction. Strauss v. Chubb
Indem. Ins. Co., 771 F.3d 1026, 1030 (7th Cir. 2014) (citing
Marotz v. Hallman, 734 N.W.2d 411, 421 (Wis. 2007)). The goal
of contract construction is to effectuate the intent of the con-
tracting parties. Wadzinski v. Auto-Owners Ins. Co., 818 N.W.2d
819, 824 (Wis. 2012). To accomplish this goal, we will read the
American National policy in accordance with its ordinary
meaning, as that meaning would be understood “by a
reasonable person in the position of the insured” (here,
4 The “fixing of the boundary between questions of law and questions
of fact” is a matter of federal procedural law, not state substantive law, in
diversity actions. Dilworth v. Dudley, 75 F.3d 307, 309 (7th Cir. 1996). As
will be shown below, this case involves the interpretation of an unambig-
uous contract and a statute. These are questions of law. Util. Audit, Inc. v.
Horace Mann Serv. Corp., 383 F.3d 683, 687 (7th Cir. 2004); Masters v. Hesston
Corp., 291 F.3d 985, 989 (7th Cir. 2002). We note that the same is true under
Wisconsin law. Town Bank v. City Real Est. Dev., LLC, 793 N.W.2d 476, 483
(Wis. 2010); MercyCare Ins. Co. v. Wis. Comm’r of Ins., 786 N.W.2d 785, 793
(Wis. 2010).

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8 No. 22-3053
Jadair). Am. Fam. Mut. Ins. Co. v. Am. Girl, Inc., 673 N.W.2d 65,
73 (Wis. 2004).
If the relevant policy language is unambiguous, we will
enforce it as written. Johnson Controls, Inc. v. London Market,
784 N.W.2d 579, 586 (Wis. 2010). If the policy language is
ambiguous, Wisconsin law generally requires us to construe
it in favor of the insured. Inter-Ins. Exch. of Chi. Motor Club v.
Westchester Fire Ins. Co., 130 N.W.2d 185, 188 (Wis. 1964). But,
before we do, we can try to resolve such ambiguities by
relying on extrinsic evidence to cast light on the parties’
intent. Town Bank, 793 N.W.2d at 484.
In applying the law to the facts of this case, we employ the
three-step framework laid out by the Wisconsin Supreme
Court in American Girl. At the first step, “we examine the facts
of the insured’s claim to determine whether the policy’s
insuring agreement makes an initial grant of coverage.” Am.
Girl, 673 N.W.2d at 73. If there is an initial grant of coverage,
we will proceed to the second step, where we “examine the
various exclusions [in the policy] to see whether any of them
preclude coverage of the present claim.” Id. If a particular
exclusion seems to preclude coverage, we will move to the
third step, where we “look to see whether any exception to
that exclusion reinstates coverage.” Id.
There is no dispute as to step one: the Cessna was the
subject of American National’s policy, and the policy makes
an initial grant of coverage over Jadair’s claim. But Jadair’s
claim falters at steps two and three, because the policy

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No. 22-3053 9
contains an exclusion that precludes coverage of the accident,
and no exception to the exclusion reinstates coverage.5
Item Nine of the policy’s Coverage Identification Page
states that the Cessna must be operated by a pilot with a
current and valid FAA medical certificate. It then explicitly
states that “THERE IS NO COVERAGE” if the pilot lacks such
a certificate. As Jadair rightly conceded at oral argument, this
provision is an exclusion under Wisconsin law because it
precludes coverage of an otherwise insured loss where the
pilot of the Cessna does not have FAA medical certification.
Progressive N. Ins. Co. v. Hall, 709 N.W.2d 46, 52 (Wis. 2006)
(stating that an exclusion is “a provision that eliminates
coverage under a particular policy where, were it not for the
exclusion, coverage would have existed”). And, because
Schmutzler undisputedly lacked a current and valid FAA
medical certificate at the time of the accident, this exclusion
precludes coverage of Jadair’s claim.
But, as Jadair sees it, the road does not end there.
According to Jadair, the Endorsement to Item Nine creates an
exception to Item Nine’s medical-certificate exclusion. And
this exception, Jadair argues, reinstates coverage of the
present claim.
Under Wisconsin law, an endorsement “may add to,
modify, or supplant” the provisions of an insurance policy.
Romero v. W. Bend Mut. Ins. Co., 885 N.W.2d 591, 596 (Wis. Ct.
5 As we discuss the various provisions of the policy, it would be help-
ful to the reader to have a copy of those provisions on hand. See supra at
2–4.

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10 No. 22-3053
App. 2016). 6 As a general rule, an endorsement is to be read
along with the remainder of the policy. Id. An endorsement
will not be read to “abrogate[], waive[], limit[], or modif[y]”
any provision of an insurance policy unless (1) the
endorsement expressly states that its provisions are
“substituted for those in the body of the policy” or (2) the
endorsement and the policy irreconcilably conflict with one
another. Westchester Fire, 130 N.W.2d at 188 (quoting John
Appleman, Insurance Law and Practice § 7538 (1943)). Because
neither circumstance presents itself here, the Endorsement
leaves Item Nine’s medical-certificate exclusion undisturbed.
First, the Endorsement does not expressly substitute its
provisions for those found in Item Nine. Jadair relies heavily
on the line at the top of the Endorsement page, which states
that the Endorsement “CHANGES [THE] POLICY.” But the
Endorsement goes on to say that it “completes or changes”
Item Nine. The word “completes” indicates that the
Endorsement may be read as adding to, rather than
displacing, Item Nine’s provisions. Indeed, that is the most
sensible way to read the Endorsement, since, as we will
explain next, the terms of the Endorsement are perfectly
consistent with those of Item Nine.
Second, there is no irreconcilable conflict between Item
Nine’s medical-certificate exclusion and any provision of the
Endorsement. To understand Jadair’s arguments to the
contrary, we must examine the language of Item Nine and the
6 In applying Wisconsin law, we are bound only by the decisions of
the Wisconsin Supreme Court. But the decisions of Wisconsin’s interme-
diate appellate courts “provide significant guidance” as well. United States
v. Glispie, 943 F.3d 358, 367 n.13 (7th Cir. 2019).

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No. 22-3053 11
Endorsement in some detail. Item Nine lists three things that
any pilot of the Cessna “must have,” including: (1) a current
and valid FAA medical certificate, (2) flight review, and (3) a
pilot certificate. The next sentence of Item Nine states that
“THERE IS NO COVERAGE IF THE PILOT DOES NOT
MEET THESE REQUIREMENTS.” The Endorsement is a bit
different. Like Item Nine, it states that the pilot of the Cessna
“must have” an FAA medical certificate, flight review, and a
pilot certificate. But it does not expressly state, as does Item
Nine, that “THERE IS NO COVERAGE IF THE PILOT DOES
NOT MEET THESE REQUIREMENTS.” The Endorsement
omits this language and instead states that “[t]here is no
coverage if the pilot does not meet the qualifications or
requirements specified below.” And below that sentence,
these requirements (not found in Item Nine) are listed:
These additional requirements (which we will call the
“endorsement-specific requirements”) indicate that the pilot
of the Cessna must have a certain amount of flight experience
or “[o]therwise” be David Schmutzler. Of course, Schmutzler
satisfied the latter condition.
Jadair argues that the Endorsement abrogated Item Nine’s
medical-certificate exclusion by omitting Item Nine’s express
provision that “THERE IS NO COVERAGE” if the pilot of the
Cessna lacks a medical certificate. We disagree. While it is true
that the Endorsement does not repeat Item Nine’s explicit

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12 No. 22-3053
statement that coverage is excluded if the Cessna’s pilot does
not have a medical certificate, nothing in the Endorsement is
inconsistent with that statement either. Indeed, the
Endorsement still says (like Item Nine itself) that the pilot
“must have” a current and valid medical certificate. Because
there is no conflict between Item Nine and the Endorsement,
we read the latter as supplementing—not supplanting—the
former. Westchester Fire, 130 N.W.2d at 188.
This reading is reinforced by the Endorsement’s statement
that it “completes or changes” Item Nine (emphasis added).
As such, we are untroubled by the Endorsement’s failure to
expressly exclude coverage when the pilot of the Cessna lacks
a current and valid medical certificate. That express exclusion
is found in Item Nine, which remains operative. See Romero,
885 N.W.2d at 596 (stating that an endorsement is to be “read
along with” the rest of the insurance policy).
Jadair also contends that the endorsement-specific
requirements displace the medical-certificate requirement
and all other pilot requirements in Item Nine. In support,
Jadair points to the language “Otherwise, David Schmutzler”
and argues that this effectively exempts him from all pilot
requirements (because, after all, he was David Schmutzler),
including the need to have a medical certificate. But this is a
strained reading of the Endorsement.
The Endorsement states that “[t]here is no coverage if the
pilot does not meet” the endorsement-specific requirements.
But it does not follow from that statement that there is
coverage whenever the pilot does meet only the endorsement-
specific requirements. Indeed, the Endorsement itself makes
clear that, in addition to the endorsement-specific
requirements, any pilot of the Cessna “must have” a current

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No. 22-3053 13
and valid medical certificate. This provision would be
meaningless if satisfying the endorsement-specific
requirements was sufficient to trigger coverage, as Jadair
contends. Md. Arms L.P. v. Connell, 786 N.W.2d 15, 25 (Wis.
2010) (“When possible, contract language should be
construed to give meaning to every word, ‘avoiding
constructions which render portions of a contract
meaningless, inexplicable or mere surplusage.’”) (quoting
Kasten v. Doral Dental USA, LLC, 733 N.W.2d 300, 315 (Wis.
2007)).
The best way to read the endorsement-specific
requirements is to interpret them as additional requirements
that the pilot of the Cessna must meet under the policy, on top
of the medical-certificate requirement in the Endorsement
and Item Nine. Thus, even though Schmutzler satisfied the
endorsement-specific requirements, he was still bound by
Item Nine and the Endorsement’s medical-certificate
requirement, and he failed to satisfy it. The consequence of
that failure, as Item Nine states, is exclusion of coverage for
the accident. Nothing in the Endorsement changes that.
In sum, we find that American National’s policy
unambiguously excludes coverage for any accident, like this
one, where the pilot lacks a valid and current FAA medical
certificate. But even if the policy were ambiguous on its face,
we would interpret it as we have. It is true that ambiguous
provisions in an insurance policy are generally to be
construed in favor of the insured. Westchester Fire, 130 N.W.2d
at 188. However, extrinsic evidence may be used to clarify an
ambiguous insurance policy, and Wisconsin courts will not
distort a policy to cover risks that the insurer did not

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14 No. 22-3053
contemplate and for which it has not been paid. Coppins v.
Allstate Indem. Co., 857 N.W.2d 896, 904 (Wis. Ct. App. 2014).
Here, even if the policy’s medical-certificate requirement
were ambiguous, Schmutzler’s insurance application resolves
the ambiguity. Schmutzler listed himself on the application as
the one authorized pilot of the Cessna and indicated that he
had an FAA medical certificate. Schmutzler initialed a section
called “Minimum Pilot Requirements,” which clearly states
that “there is no coverage” under the policy unless the
Cessna’s pilot is both “designated” on the application and has
“the certificates … indicated” and is “properly qualified for
the flight involved.” Thus, the application makes clear that
any pilot flying the Cessna, including Schmutzler, must have
an FAA medical certificate, and no reasonable jury would find
otherwise on the present record. See Bos. Five Cents Sav. Bank
v. Sec’y of Dep’t of Hous. & Urb. Dev., 768 F.2d 5, 8 (1st Cir. 1985)
(stating that the interpretation of an ambiguous contract may
be taken away from the jury where the extrinsic evidence is
“so one-sided that no reasonable person could decide the
contrary”).
B. Whether Wis. Stat. § 631.11(3) Applies
Jadair next contends that, even if the medical-certificate
exclusion applies to its claim, the claim must be covered
under Wis. Stat. § 631.11(3). That provision states:
No failure of a condition prior to a loss and no
breach of a promissory warranty constitutes
grounds for rescission of, or affects an insurer’s
obligations under, an insurance policy unless it
exists at the time of the loss and either increases

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No. 22-3053 15
the risk at the time of the loss or contributes to
the loss.
Jadair argues that, under this statute, American National
cannot withhold coverage absent some showing that
Schmutzler’s failure to obtain a medical certificate increased
American National’s risk or otherwise contributed to the
accident. And American National cannot make this showing,
Jadair argues, because it is undisputed that the accident was
caused by a mechanical problem with the Cessna, not a
medical problem with Schmutzler.
The problem with Jadair’s argument is that § 631.11(3)
does not apply here. The statute only applies to cases
involving the “failure of a condition” or the “breach of a
promissory warranty.” In Fox v. Catholic Knights Insurance
Society, the Wisconsin Supreme Court treated these terms as
largely synonymous and held that § 631.11(3) only applies to
conditions subsequent. 665 N.W.2d 181, 190 (Wis. 2003).
But the policy’s medical-certificate requirement is not a
condition subsequent. Rather, as we explained above, it is an
exclusion of coverage in cases where the requirement is not
satisfied.
Wisconsin courts have long recognized the difference
between exclusions and conditions subsequent. While
conditions subsequent (and warranties) provide for the
avoidance of liability for a covered loss if they are breached,
exclusions declare that there never was coverage for a
particular loss in the first place. Bortz v. Merrimac Mut. Ins. Co.,
286 N.W.2d 16, 19–21 (Wis. Ct. App. 1979); see also McCoy v.
Nw. Mut. Relief Ass’n, 66 N.W. 697, 699 (Wis. 1896) (holding
that conditions are subject to waiver and estoppel while

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16 No. 22-3053
exclusions are not); Maxwell v. Hartford Union High Sch. Dist.,
814 N.W.2d 484, 491–92 (Wis. 2012) (same). As we have seen,
the policy’s medical-certificate requirement operates as an
exclusion: it “‘limits the scope of coverage,’ ‘tak[es] out …
events otherwise included within the defined scope of
coverage,’ and ‘expressly refuse[s] to assume a specific hazard
or risk.’” Kutchera v. State Farm Fire & Cas. Co., 560 F. Supp. 3d
1242, 1248 (W.D. Wis. 2021) (quoting Bortz, 286 N.W.2d at 19–
21). Because the medical-certificate requirement is an
exclusion and not a condition subsequent, § 631.11(3) has no
application to the present case. Fox, 665 N.W.2d at 190; see also
Kutchera, 560 F. Supp. 3d at 1246–50 (holding that § 631.11(3)
does not apply to exclusions, given Wisconsin courts’
longstanding distinction between exclusions and conditions).
C. Jadair’s Motion to Certify a Question to the Wisconsin
Supreme Court
Finally, Jadair moves to certify the following question to
the Wisconsin Supreme Court:
Does Wis. Stat. § 631.11(3) require that the
insurer prove a causal connection under an
aircraft insurance policy between the accident
and the failure of the insured to comply with
federal aviation safety-related regulations?
“Our rules permit us to certify state-law questions to a
state supreme court when the answer will control the
outcome of a case and the state court accepts such
certifications.” Cothron v. White Castle Sys., Inc., 20 F.4th 1156,
1165 (7th Cir. 2021) (citing 7th Cir. R. 52(a)). But just because
we can certify a question does not mean that we should.
Unneeded certification orders waste the time of the litigants

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No. 22-3053 17
who appear before us. They also burden our esteemed
colleagues in the state supreme courts and endanger the
important purposes of federalism. See Cassirer v. Thyssen-
Bornemisza Collection Found., 69 F.4th 554, 587 (9th Cir. 2023)
(Bea, J., dissenting) (stating that unwarranted certification
requests “deplete our reservoir of comity” with the state
supreme courts). So we will only certify a state-law question
when doing so is particularly necessary.
In determining whether a particular question warrants
certification, we consider several factors. Most importantly,
“we must find ourselves ‘genuinely uncertain’ about the
answer to the state-law question before considering
certification.” Cothron, 20 F.4th at 1166 (quoting In re
Hernandez, 918 F.3d 563, 570 (7th Cir. 2019)). The question this
case raises does not meet that test, and so we will not waste
the Wisconsin Supreme Court’s time with it.
Jadair essentially asks the Wisconsin Supreme Court to
determine the scope of § 631.11(3)’s applicability. But the
court already did this in Fox, when it held that the statute only
applies to conditions subsequent. 665 N.W.2d at 190. As we
have explained, the policy’s medical-certificate requirement is
not a condition subsequent, so the statute does not apply.
Jadair urges that Fox was not decided in the context of
aviation insurance, but we do not see why that matters.
Section 631.11(3), on its face, applies to all insurance policies,
and Jadair has given us no reason to believe that the
Wisconsin Supreme Court would interpret the statute
differently for different types of insurance. 7 While Fox is not
7 Jadair spends a significant portion of its briefing summarizing the
varying approaches other states have taken regarding whether and when
an aviation insurer must prove a causal connection between an insured’s

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18 No. 22-3053
factually identical to this case, we are “confident in
proceeding under the guidance” that it provides. Bernstein v.
Bankert, 733 F.3d 190, 221 (7th Cir. 2013). Accordingly, Jadair’s
motion to certify its question is denied.
III. CONCLUSION
For the reasons stated above, the judgment of the district
court is AFFIRMED, and Jadair’s motion to certify a question
to the Wisconsin Supreme Court is DENIED.
violation of a particular provision of a policy and a claimed loss. But the
laws of states other than Wisconsin provide little help here.

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