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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

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

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

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

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