When South Dakota rancher Perle O’Daniel discovered that hundreds of his cattle had been stolen, he assumed that his insurance company would cover the loss. However, on Nov. 1, 2005, the 8th Circuit Court of Appeals held the insurer had no liability.

O’Daniel purchased an insurance policy from Minnesota-based NAU Country Insurance Co. for $1,400,400 of coverage. The policy covered physical loss of his livestock due to theft. However, it contained several exclusions, one of which was loss “by wrongful conversion