Archer Daniels Midland Co. v. Hartford Fire Insurance (243 F.3d 369, 2001)

EASTERBROOK, Circuit Judge.

For many years Archer Daniels Midland (adm) bought $50 million of business-interruption coverage from Employers’ Insurance of Wausau. But when Wausau quoted a price increase of roughly $19,000 (from $43,750 to $62,500) for adm’s 1993 fiscal year, adm deemed the premium excessive and went shopping for a bargain. This attempt to save $19,000 has cost adm $50 million, for the replacement insurance did not cover the losses adm sustained as a result of the flood in the upper Mississippi River basin during 1993, the greatest in the nation’s history. In this litigation under the diversity jurisdiction, adm asked the court to “reform” the policy it purchased from Hartford Fire Insurance Company so that it would cover adm’s loss.

The flood inundated about eight million acres of farmland and disrupted transportation on the Mississippi and Missouri Rivers and their tributaries. Much of adm’s business depends on corn, which increased in price by about 15