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Third Circuit Holds Harassment Exclusion Bars Coverage for Sexual Assault Suit Under Pennsylvania Law

In Rice Enterprises LLC v. RSUI Indemnity Co., the Third Circuit Court of Appeals affirmed the district court’s finding that the insured was not entitled to coverage from its employer’s liability insurer or its umbrella...more

Federal Court Finds No Coverage for Mouthwash Tainted From Auto Cleanser Equipment

Applying well-settled Wisconsin law, a federal district court found that an insurer had no duty to indemnify an oral hygiene product manufacturer for tainted products after determining that the losses did not result from an...more

No Paying Over Slow Milk? Wisconsin Appellate Court Finds Intentional Act by Cattle Feed Supplier May Be “Occurrence” Under CGL...

In Riverback Farms LLC v. Saukville Feed Supplies Inc., a panel of the Wisconsin Court of Appeals found that an intentional act may still constitute an “occurrence” under a commercial general liability policy, reversed the...more

11th Cir. Affirms That Georgia’s Implied Waiver Doctrine Cannot Be Used to Create Coverage

In Century Communities of Georgia LLC v. Selective Way Insurance Co., the Eleventh Circuit Court of Appeals affirmed that the Georgia Supreme Court’s 2012 opinion in Hoover v. Maxum Indemnity Co. does not apply to “coverage...more

Ohio Supreme Court Finds Insured’s Ransomware Payment Not Covered Under Business Owners Policy

In EMOI Services LLC v. Owners Insurance Co., No. 2021-1529 (Ohio Dec. 27, 2022), the Ohio Supreme Court found that there was no coverage for a ransomware attack because there was no direct physical loss as required under the...more

Eleventh Circuit Finds Claims-Made Policy’s “Correlating Claims” Provision Substantially Similar to “Related Claims” Provisions

In Datamaxx Applied Technologies Inc. v. Brown & Brown Inc., the Eleventh Circuit Court of Appeals affirmed the district court’s grant of summary judgment to the insurer, finding no merit in the insured’s argument that the...more

Louisiana Supreme Court Finds “Assault and Battery Exclusion” Barred Coverage for Kidnapping at Insured’s Motel

In granting summary judgment to the insurer and finding no duty to defend, Louisiana’s highest court reversed a trial court’s ruling on the basis of the “clear and unambiguous” assault and battery exclusion in a commercial...more

Georgia Federal Court Extinguishes Fire Claim Because of Insured’s Failure to Update Insurer on Home Use

In Mehic v. Allstate Property and Casualty Insurance Co., the U.S. District Court for the Northern District of Georgia determined that an insured did not satisfy a condition precedent to coverage under a homeowners policy —...more

Virginia Federal Court Orders Suppliers of Contaminated Fruit to Reimburse Subrogated Insurer for Defense of Smoothie Cafes

Sentinel Insurance Co. v. VLM Foods Inc. arose after a hepatitis A outbreak was traced back to contaminated strawberries used and sold by several insured smoothie cafe franchises. The insured tendered all of the outbreak...more

Arizona Supreme Court Finds That Reasonableness of Insurer’s Refusal to Consent to Settlement Under D&O Policy Is in the Eye of...

In Apollo Education Group Inc. v. National Union Fire Insurance Company of Pittsburgh, the Arizona Supreme Court found that the reasonableness of the insurer’s decision to refuse to consent to settlement under a directors and...more

Missouri Federal Court Finds New York Choice-of-Law Provision Does Not Inhibit Insured’s Assertion of Missouri-Specific Public...

In Maritz Holdings Inc. v. Certain Underwriters at Lloyd’s London, a federal court in Missouri denied an insurer’s motion to dismiss the insured’s assertion of a vexatious refusal to pay claim based on an obscure...more

South Carolina Federal Court Finds No Coverage for Faulty Workmanship Damages Discovered Years After Occurrence-Based Policy...

Potential Six-Year Delay in Notice of Flood and Mold Damage “Substantially Prejudiced” Insurer - In Atain Specialty Insurance Company v. Carolina Professional Builders, LLC et al., 2:18-cv-2352-BHH (D.S.C. Oct. 2, 2020),...more

Seventh Circuit Rejects Insured’s “Claim Within a Claim” Argument

The Seventh Circuit Court of Appeals recently had occasion to clarify the parameters of a “claim” in insurance policies. In Market Street Bancshares Inc. v. Federal Insurance Co., Judge Kanne penned an opinion holding that a...more

Pennsylvania Court Ices General Reservation of Rights Letters: Insurers Must Specify “Emergent Coverage Issues”

In Selective Way Insurance Co. v. MAK Services Inc., the Superior Court of Pennsylvania reversed an insurer-favorable summary judgment after finding that its reservation of rights letter was insufficient....more

South Carolina Supreme Court’s Quiet Erosion of Insurers’ Attorney-Client Privilege Rights

One decision that flew under the radar in 2019 continues the recent trend of courts to dispense, under among other things the previously discussed “at-issue” waiver doctrine, with insurers’ fundamental rights to...more

War of the Words: Ninth Circuit Reverses Judgment for the Insurer in Rare War Exclusion Case

In Universal Cable Prods. LLC v. Atlantic Specialty Ins. Co., 2:16 cv-04435 PA, (9th Cir. July 12, 2019), the Ninth Circuit reversed the district court’s determinations as it relates to the application of two war exclusions....more

Form Over Substance? High Court Agrees to Take a Look at an Old Fifth Circuit Rule Requiring Formal Objection

A recent grant of certiorari will determine whether formality should prevail over the reality of what the trial court unquestionably knows. On June 3, 2019, the Supreme Court granted certiorari in Holguin-Hernandez v. United...more

California Federal Court Holds Scope of Duty to Defend Is Determined by the Language of the Contract

In Harper Construction Co. v. National Union Fire Insurance Co. of Pittsburgh, the Southern District of California rejected an insured’s attempt to expand a CGL policy’s definition of “suit” to encompass mere demands without...more

Clearing The Air: Tenth Circuit Strikes Down An Indoor Air Quality Exclusion, Citing Ambiguity

Ambiguity strikes again. While the heavily litigated pollution exclusion is well-known in the insurance world, its progeny—the indoor air exclusion—only recently has started making its way around the block. ...more

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