In One Beacon Ins. Co. v. Crowley Marine Services, Inc., ___F.3d ___, 2011 WL 3195292 (5th Cir. (Tex.) July 28, 2011), the U.S. Court of Appeals for the Fifth Circuit upheld an insurer's denial of coverage for a party not expressly named as an additional insured.

Crowley, owned and operated vessels, and Tubal-Cain repaired ships. While working on a Crowley vessel, a subcontractor for Tubal-Cain purportedly was injured and filed suit against Tubal-Cain and Crowley in Texas state court. Crowley sought a defense and indemnity from Tubal-Cain and coverage from One Beacon as an additional insured under a maritime comprehensive liability policy issued to Tubal-Cain.

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