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Intentional Loss Exclusion Could Apply Even to Unintended Damage, Says the Tenth Circuit

The Tenth Circuit recently held that, under Kansas law, an intentional loss exclusion precludes coverage for damage caused by an intentionally set fire even if the actual resulting damage is unintended. In Taylor et al. v. LM...more

Intentional Act Without Intent to Harm May Not Be an Occurrence

An intentional act may not be an “occurrence” even when there is no intent to cause harm, according to a California appellate court’s recent ruling in Ghukasian v. Aegis Security Insurance Co.1 Ghukasian involved an insured...more

New York Court Holds Coverage for Excavation Damage Precluded by Earth Movement Exclusion

According to a recent ruling by a New York appellate court, coverage for excavation damage is precluded by the policy’s earth movement exclusion. In 3502 Partners LLC v. Great American Insurance Co. of New York, Case No....more

Accepting Coverage for Part of a Claim May Subject an Insurer to the Appraisal Process Under Tennessee Law

Accepting coverage for part of a claim may subject an insurer to a policy’s appraisal process when the extent of covered damage is in dispute, according to a recent ruling issued by the Eastern District of Tennessee....more

Second Circuit Holds No Coverage for COVID-19 Business Interruption Losses

The Second Circuit has now joined the Fifth, Sixth, Seventh, Eighth, Ninth, Tenth, and Eleventh Circuits in holding that no insurance coverage exists for business interruption losses caused by the Covid-19 pandemic and the...more

Court in Montana Applies Anti-Concurrent Causation Clause to Earth Movement Exclusion

A district court in Montana recently applied an anti-concurrent clause in a property insurance policy to preclude coverage based on an earth movement exclusion. In Ward v. Safeco Ins. Co. of Amer., No. 1:19-CV-0133-SPW, 2021...more

Claim Investigation Not Necessarily Protected by Work Product Doctrine in Illinois

In determining when the work product doctrine is triggered, the Northern District of Illinois recently held that, rather than adopting a bright-line rule, the issue should be decided on a case-by-case basis at the court’s...more

Wind Before Storm May Blow Away Flood Exclusions

Flood exclusions may not apply when floods are preceded by winds strong enough to independently cause the loss, according to a recent decision issued by the Western District of Louisiana. In Doxey v. Aegis Security Ins. Co.,...more

Reasonableness of Insurer’s Coverage Decision Determined by Evidence Available at Time of Decision

The Eighth Circuit Court of Appeals recently held that, under Iowa law, an insurer is not liable for breach of contract or bad faith if its coverage decision was objectively reasonable at the time it was made. In Hallmark...more

Appraisal Process Tolls Contractual Suit Limitation Period Even For Non-Covered Claims

The Eleventh Circuit Court of Appeals recently held that, under Georgia law, an appraisal process tolled a commercial property policy’s two-year contractual suit limitation period even for non-covered claims....more

Florida Court Holds Rust and Corrosion is “Act of Nature”

A Florida court recently held that rust and corrosion of water pipes is an “act of nature,” and, thus, was excluded from coverage under a homeowner’s insurance policy. In Dodge v. People’s Trust Insurance Company, 2021 WL...more

South Carolina Allows Depreciation of Labor Costs In ACV Calculation

Insurers in South Carolina may now depreciate both labor costs and material costs when determining the “actual cash value” (ACV) owed to policyholders for property damage....more

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