In West Bend Mutual Insurance Co. v. Calumet Equity Mutual Insurance Co. (2018AP435), the Court of Appeals District II held that farming work is not a “domestic duty” covered by an insurance policy.

The case arises from an accident where plaintiff David Schaefer’s cows escaped and caused a collision on a nearby road. West Bend insured the person injured in the crash and recovered $114,000 from Schaefer. Calumet insured the property where Schaefer raised his cattle. In the instant case, West Bend and Schaefer sought $114,000 from Calumet, arguing Schaefer was an insured under the Calumet policy.

The Calumet policy, in part, defined “insured” as “persons in the course of performing domestic duties that relate to the ‘insured premises.’” The court ruled that Schaefer was not an insured under the Calumet policy because maintaining his cattle was not a “domestic duty” under the policy. Farming is not related to the management of a private place of residence, so Schaefer’s duties related to the cattle do not fall under “domestic duties” as defined by previous courts. The court declined to expand the term “domestic duties” to include any activity occurring on the insured premises.