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Top Developments: 2025 - Issue 2

Bob Robison Com. Flooring Inc. v. RLI Ins. Co., 2025 U.S. App. LEXIS 6369 (8th Cir., Mar. 19, 2025) - Eighth Circuit, predicting Arkansas law, concludes that an ensuing loss exception to a “Defects, Errors, Or Omissions”...more

First Circuit Finds No Coverage For Subcontracted Faulty Work

After almost two years' deliberation, the First Circuit last week issued its long-awaited decision in Admiral Ins. Co. v. Tocci Bldg. Corp.: affirming on other grounds, and leaving in place a district court decision that...more

First Circuit Limits Insurers’ Right to Recoup Defense Costs, Settlement Payments

Weighing in on an issue that has divided courts nationwide, the U.S. Court of Appeals for the First Circuit has ruled that an insurer under Massachusetts law has no right to recoup defense costs, or amounts the insurer pays...more

First Circuit Holds That Notice Provisions in Claims Made Policies Must Be Strictly Enforced

In President & Fellows of Harvard College v. Zurich Am. Ins. Co., the United States Court of Appeals for the First Circuit ruled that Harvard was not entitled to coverage under an excess claims-made and reported policy issued...more

Top Developments – November 2022

SPOTLIGHT: Third Circuit Court of Appeals Affirms No Coverage for Sex Trafficking Claims - In Nautilus Insurance Co. v. Motel Management Services Inc., the Court of Appeals granted a motion for judgment on the pleadings...more

MA SJC Rules Attorney’s Fees Awarded Under G. L. c. 93A Are Not Covered by Liability Policy

In Vermont Mutual Insurance Company v. Poirier, the Massachusetts Supreme Judicial Court (SJC) ruled that attorney’s fees awarded under M.G. L. c. 93A are not covered by a Businessowner’s Liability Policy, because such fees...more

Massachusetts Federal Court Rejects Adria Towers, Finds Construction Defects Not an “Occurrence”

In an important ruling for insurers, U.S. District Court Judge Patti Saris found that Massachusetts does not follow the position taken in Cypress Point Condo Association v. Adria Towers, LLC, 226 N.J. 403, 418 (2016), i.e.,...more

Massachusetts Business Court Addresses Defense Cost Allocation and Non-Cumulation Provisions in Long-Tail Context

A business court in Massachusetts has weighed in on two key issues affecting allocation of insurance coverage for long-tail liabilities in Massachusetts. Specifically, in Crosby Valve LLC et al. v. OneBeacon America Insurance...more

When Can Liability Insurers Sue Appointed Underlying Defense Counsel for Malpractice?

Insured gets sued. Insurer hires defense counsel to represent insured. Defense counsel takes over the case, and eventually, the case ends. Most of the time, the carrier and its insured will be satisfied with the result. There...more

Connecticut Appellate Court Breaks New Ground on Policy Exhaustion

The Connecticut Appellate Court recently issued a wide-ranging opinion, Continental Casualty Co. v. Rohr, Inc., which significantly extended the current restrictive view on when a general liability policy can be considered...more

First Circuit Holds Conflicting Policy Provisions Require Coverage for Petroleum Spill

On December 18, 2020, the U.S. Court of Appeals for the First Circuit held that conflicting provisions in an excess policy required an insurer to cover the costs a transportation company incurred to clean up a fuel spill,...more

Connecticut Supreme Court Finds Duty to Defend When Case Law is Uncertain

The Connecticut Supreme Court recently addressed whether an insurer has a duty to defend when faced with legal uncertainty as to whether coverage is owed: for example, when there is no Connecticut case law on point, and...more

The Insurer’s Duty to Defend and Pre-Suit Demand Letters What Constitutes a “Suit”?

Commercial general liability (CGL) policies typically provide that an insurer will defend a “suit” that seeks covered “damages” that the insured may be “legally obligated to pay.” This seems simple enough. But can an...more

COVID Restrictions Struck in Wisconsin – Other Challenges Likely

Tensions between safety, public health, and economic considerations broke into open view again yesterday, as the Wisconsin Supreme Court struck down an Emergency Order issued by the Secretary of the Wisconsin Department of...more

First Circuit: No Coverage, No Duty to Investigate Alleged Loss Prior to Policy Period

On April 1, 2020, the First Circuit, applying Massachusetts law, issued a potentially useful decision addressing the Montrose “known loss” language in ISO Form CGL policies. In Clarendon National Insurance Company v....more

NY Federal Court Refuses to Consider Extrinsic Evidence of an Insurer’s Claim Handling for a Different Policyholder

In Spandex House v. Hartford Fire Insurance Company, an insurer prevailed in a breach of contract and declaratory judgment action arising from an underlying suit against its insured, Spandex House Inc. In the underlying...more

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