To Fee Or Not To Fee, That Is The Question: The Florida Supreme Court Finds Coverage For Proposal For Settlement Sanctions In Favor Of The Plaintiff Under An Automobile Liability Policy In Macedo II

by Butler Weihmuller Katz Craig LLP

To understand the implications of Macedo II, it is important to understand what brought us here. It’s a long and bumpy road, but understanding what brought us here will be critical in order to understanding how to go forward.

Prior to the recent Florida Supreme Court’s decision in Government Employees Insurance Company v. Macedo, 2017 WL 2981812 (Fla. July 13, 2017) (Macedo II), a conflict existed between Florida’s District Courts of Appeal over whether an automobile liability insurance policy provided coverage for attorney’s fees and costs imposed against an insured defended by the insurance carrier.[1]  Due to the conflicting interpretations of what the court deemed substantially similar policy language, the Supreme Court accepted conflict jurisdiction in Government Employees Insurance Company v. Macedo, 2017 WL 2981812 (Fla. July 13, 2017), and held that coverage for such sanctions existed.  To fully understand the impact of Macedo II, we must examine typical policy language governing this issue, the language of the GEICO policy in Macedo II, and the conflicting appellate decisions that gave rise to the Supreme Court’s decision. 

The Supplementary Payments section in a typical personal or commercial automobile insurance policy usually includes language similar to, “We [the insurance carrier] will pay for the insured all costs taxed against the insured in any suit against the insured we defend.”  Further, this section usually includes a provision that the insurance carrier will pay “all reasonable expenses incurred by the insured at our request….”  However, the policy language in the GEICO policy at issue in Macedo II was a little different because it did not specifically provide coverage for the taxable costs of the plaintiff following an adverse result and only agreed to pay “all reasonable costs incurred by an insured at our request.”

In one of the cases addressed by the Florida Supreme Court, Steele v. Kinsey, 801 So. 2d 297 (Fla. 2d DCA 2001), Ms. Kinsey held an automobile liability insurance policy with United Automobile Insurance Company (United).  Ms. Kinsey was involved in an automobile accident with Mr. Steele that caused him injuries, and Mr. Steele subsequently sued Ms. Kinsey.  As with most other insurance policies, Ms. Kinsey’s policy gave United exclusive control over settling or litigating any claim against her covered under the policy.  During the course of the litigation, Mr. Steele served a proposal for settlement for the policy limits of $10,000, but United rejected the proposal for settlement.  Mr. Steele, United, and Ms. Kinsey then entered into a Cunningham agreement (an agreement to try bad faith allegations first) and also agreed to allow the court to decide whether United’s policy provided coverage to Ms. Kinsey for any attorney’s fees and costs she may owe due to the failure to accept the proposal for settlement.  The trial court ruled there was no coverage, and Mr. Steele appealed the decision.

The Second District Court of Appeal agreed with the trial court’s decision and held that the supplementary payments provision in the policy stating that United would pay “expenses incurred at our request” did not include attorney’s fees and costs under the proposal for settlement statute.  Based on the definition of “request” found in the dictionary, the court held that the “insurer intended to pay for expenses that it had authorized and over which it had control, such as the selection of a service or product of known value or cost.”  Therefore, these subsequent fees and costs were not “incurred at [the insurer’s] request.” 

Relying on another case directly in conflict, Florida Insurance Guaranty Association v. Johnson, 654 So. 2d 239 (Fla. 4th DCA 1995), Mr. Steele argued that United’s decision not to settle the case pursuant to the proposal for settlement caused the litigation to continue and increased expenses and attorney’s fees.  However, while the Kinsey court recognized that public policy might dictate that the insurer who had the sole right to accept or reject the proposal for settlement should be ultimately responsible for paying extra expenses as a result of the rejection, the court held the supplemental payment provisions in United’s policy were unambiguous and no coverage was owed for the attorney’s fees awarded to Mr. Steele against United’s insured.   

On the other hand, the First District Court of Appeal in Government Employees Insurance Company v. Macedo, 190 So. 3d 1155 (Fla. 1st DCA 2016) (Macedo I), held that the policy provision providing coverage for “other reasonable expenses incurred at our request” in an automobile policy provided coverage to the insured for attorney’s fees and costs awarded against the insured, if triggered by the rejection of a proposal for settlement.  In that case, the jury returned a verdict several times greater than the plaintiff’s proposal for settlement and the trial court awarded her fees and costs.  The First District Court of Appeal explained that GEICO’s policy provided it with the sole responsibility and right to litigate or settle a claim or lawsuit. 

The terms of the policy specifically required GEICO to pay “all investigative and legal costs incurred by us” and “all reasonable costs incurred by an insured at our request.”  The court reiterated its ruling in New Hampshire Indemnity Company v. Gray, 177 So. 3d 56 (Fla. 1st DCA 2015), which held that an insurer has the sole ability to determine whether to litigate or settle a claim.  Thus, the insurance policy provided coverage to the insured for attorney’s fees and costs awarded against the insured triggered by a rejected proposal for settlement.

Based on these differing opinions, GEICO sought review in Macedo II. The Supreme Court analyzed the same two provisions contained in GEICO’s policy, “[a]ll investigative and legal costs incurred by us” and “[a]ll reasonable costs incurred by an insured at our request.”  GEICO initially argued that the policy did not provide coverage for attorney’s fees awarded against the insured because the policy only referenced costs, which do not include attorney’s fees.  Critically, however, the index to the policy listed “Legal Expenses and Court Costs” as costs and expenses covered under the policy.  Therefore, the Florida Supreme Court found the provisions to be ambiguous. 

Specifically, the Court held that the other policy provisions providing coverage for costs, along with the index citing legal expenses, created an ambiguity regarding whether coverage for attorney’s fees was included.  Because ambiguities in an insurance policy are most always interpreted against the drafter of the insurance policy, i.e. the insurance carrier, and interpreted in favor of insurance coverage, the court held that coverage for such damages existed.

GEICO also argued that the Additional Payments section of the policy stating, “[a]ll reasonable costs incurred by an insured at our request” did not cover attorney’s fees or costs awarded against an insured following the rejection of a proposal for settlement because such fees and costs were not incurred “at [GEICO’s] request.”  Nevertheless, the Florida Supreme Court agreed with the reasoning in Gray and Johnson and held that because GEICO had control over settling and litigating the case, including rejecting the plaintiff’s proposal for settlement, it was ultimately responsible to pay and provide coverage for any attorney’s fees and costs awarded against the insured triggered by the rejection of a plaintiff’s proposal for settlement.

Now What? Ideas For Going Forward

So what do the above decisions mean to an automobile insurance carrier? Is it a foregone conclusion under all policies that coverage exists for attorney’s fees and expenses awarded against an insured following an adverse verdict triggering the penalties under a proposal for settlement?  As previously stated, most, if not all, automobile insurance policies include provisions stating that the policy will provide coverage for costs taxed against an insured and for all reasonable expenses incurred by an insured at the insurer’s request. 

These policies also provide that insurance carriers have the ultimate decision-making authority regarding the defense of an insured in a lawsuit.  Therefore, if the policy language remains unchanged, most automobile insurance policies likely provide coverage to the insured for any attorney’s fees and costs awarded against the insured when the insurance carrier declines a proposal for settlement and the jury awards a verdict greater than 25% of the amount offered.  And more importantly, as in Macedo II, such amounts are owed as supplementary payments on top of, or in excess to, the policy limit.

An insurance carrier may be able to argue that its automobile policy does not include “Legal Expenses and Court Costs” in the index to its policy, so there should be no coverage for attorney’s fees imposed against the insured.  However, the Florida Supreme Court also based its decision on the fact that GEICO had control of the litigation against its insured and had the ultimate decision-making authority regarding whether to accept or reject the proposal for settlement served by the plaintiff.  As the courts’ reasoning went, why should the insured be financially penalized if he or she did not have the ultimate authority to decide whether to accept or reject the proposal for settlement?

Due to the decision in Macedo II, an insurance company should analyze a proposal for settlement in light of this holding.  No longer will it require a finding of bad faith in order to create exposure to the insurer to satisfy the fee and cost awards, even if the total damages’ award exceeds the liability policy limits.  This means that an insurance company may be exposed to paying hundreds of thousands of dollars in attorney’s fees and costs depending upon the nature and complexity of the case. 

In other sanction scenarios under other policy types, courts have also found coverage for attorneys’ fees, unless specifically excluded.  Although statutory attorneys fees were not considered covered “damages” under a generally liability policy, Scottsdale Insurance Company v. Haynes, 793 So. 2d 1006 (Fla. 5th DCA 2001), another court found coverage for a court imposed discovery sanction award against the insured.  Tri-State Insurance Company of Minnesota v. Fitzgerald, 593 So. 2d 1118 (Fla. 3d DCA 1992).  The Fitzgerald court held that coverage for the attorney’s fees and costs awarded against the insured existed because the policy provided coverage for “all costs taxed against the insured, in any suit defended by the insurer(s)….” 

Further, in Mid-Continent Casualty Company v. Treace, 186 So. 3d 11 (Fla. 5th DCA 2015), the court found coverage for attorney’s fees and costs awarded in a faulty construction action.  The court agreed that a policy which provided coverage for “all costs taxed against the insured [it] defend[s]” owed coverage for the attorney’s fees and costs awarded to the prevailing party.  See also, Geico General Insurance Co. v. Hollingsworth, 157 So. 3d 365 (Fla. 5th DCA 2015); Geico General Insurance Co. v. Rodriquez, 155 So. 3d 1163 (Fla. 3d DCA 2014) (court costs could include attorney’s fees).  Because there was no definition of court costs in the policies that did not specifically exclude attorney’s fees, the court concluded that MCC’s policy provided coverage for the attorney’s fees and costs awarded to the Treaces. 

Of note, the court in Hollingsworth, which analyzed an automobile insurance policy, found coverage for attorney’s fees imposed on an insured triggered by plaintiff’s proposal for settlement which was rejected.  See also, Assurance Company of America v. Lucas Waterproofing Company, Inc., 581 F.Supp. 2d 1201 (S.D. Fla. 2008) (attorney’s fees and costs imposed on an insured by a contract or statute because the plaintiff prevailed, which are related to claims that are covered under the general liability policy, constitute property damage and are covered under the policy).  

Critically, the most recent commercial general liability coverage form CA 00 01 04 13 contains Supplementary Payments language as follows:

We will pay, with respect to any claim we investigate or settle, or any “suit” against an insured we defend:

*  *  *

e. All court costs taxed against the insured in the “suit.”  However, these payments do not include attorneys’ fees or attorneys’ expenses taxed against the insured.

*  *  *

No mention was made in the above cited cases that the policies involved included the same or similar language specifically excluding coverage for attorney’s fees and expenses as costs taxed against an insured now included in most, if not all, general liability policies. 

Similarly, the proposal for settlement cases discussed above in which coverage was challenged were not decided under general liability policies.  Similar to an automobile liability policy, a general liability insurer has the ultimate decision-making authority regarding whether to reject a proposal for settlement.  As such, the same rationale in Macedo II finding coverage for an insured for attorney’s fees and costs imposed against the insured can easily be applied in a general liability policy context.

Nevertheless, based upon the policy language quoted above, a commercial general liability policy should not be forced to provide coverage for attorney’s fees taxed against an insured, even if triggered due to a declined proposal for settlement.  However, if the insurance industry wants to exclude such awards, regardless of the policy type, the policy language needs to be amended to specifically say so. More litigation regarding this issue is sure to present itself in the not so distant future.


[1]  As background, pursuant to section 768.79, Florida Statutes, if a plaintiff serves a proposal for settlement that is rejected by the defendant and the plaintiff recovers a judgment in excess of 25% of the offer, the plaintiff is entitled to recover her reasonable costs and attorney’s fees incurred from the date of the filing of the proposal (assuming the plaintiff complies with strict requirements in the statute and Rule 1.442, Florida Rules of Civil Procedure).



DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Butler Weihmuller Katz Craig LLP | Attorney Advertising

Written by:

Butler Weihmuller Katz Craig LLP

Butler Weihmuller Katz Craig LLP on:

Readers' Choice 2017
Reporters on Deadline

Related Case Law

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.