News & Analysis as of

Denial of Insurance Coverage D&O Insurance Insurance Litigation

Wiley Rein LLP

Tenth Circuit Deems D&O Policy Ambiguous Based on Interplay of Coverage Grant with Managed Care Exclusion

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The United States Court of Appeals for the Tenth Circuit, applying Kansas law, has held that a D&O insurer was obligated to reimburse defense costs where a policy expressly covered antitrust claims but excluded coverage for...more

Wiley Rein LLP

Antitrust Exclusion Applies to Claims for Unjust Enrichment and Violation of Consumer Protection Laws

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Applying California law, the United States District Court for the Eastern District of California has held that an antitrust exclusion in a D&O policy bars coverage for lawsuits alleging violation of antitrust laws, violation...more

Lowenstein Sandler LLP

A Cautionary Tale Highlights the Importance of Carefully Reviewing a Warranty Letter Before Signing

Lowenstein Sandler LLP on

When buying an insurance policy, a policyholder is sometimes required to sign a warranty letter affirming that they are not aware of any impending claims nor any facts or circumstances that may reasonably give rise to a...more

Wiley Rein LLP

No Coverage for Claim Involving New Defendants and Alleging New Wrongful Acts Where Claim Relates Back to Earlier Policy Period

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The United States District Court for the Southern District of Florida, applying Florida law, has held that a D&O policy did not cover a claim against directors because the claim related back to an earlier policy period, even...more

Carlton Fields

NY Federal Court Finds “Insured v. Insured” Exclusion in D&O Policy Trumps General Allocation Clause

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On December 9, 2022, the U.S. District Court for the Southern District of New York considered whether an “insured v. insured” (IvI) exclusion applied to bar coverage for an underlying lawsuit brought against insureds under a...more

Jenner & Block

Seventh Circuit Decision Sends Warning to "Claims Made" D&O Insurance Policyholders

Jenner & Block on

The U.S. Court of Appeals for the Seventh Circuit in Hanover Ins. Co. v. R.W. Dunteman Co., 2022 WL 13769371, --- F.4th --- (7th Cir. Oct. 24, 2022), recently interpreted Illinois law on the aggregation provisions in a claims...more

Wiley Rein LLP

Insured v. Insured Exclusion Bars Coverage For Entirety of Suit Brought By Insureds and Non-Insureds

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The United States District Court for the District of Utah, applying Utah law, has held that an insured v. insured exclusion barred coverage for the entirety of a “mixed” action brought by both insured and non-insured...more

Lowenstein Sandler LLP

In the Know: The Lowenstein Insurance Recovery Group’s Tip of the Month - November 2021

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A recent Sixth Circuit decision highlights a split among courts regarding the application of the “insured v. insured” exclusion in D&O policies to “mixed” lawsuits, i.e., suits brought by multiple plaintiffs (who are both...more

Jones Day

Federal Court Rejects Application of D&O Policy's "Bump-Up" Exclusion to Merger Litigation

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Directors and Officers Liability ("D&O") insurers often attempt to rely on so-called "bump-up" exclusions in their policies as a categorical bar to the indemnification of claims arising from mergers and acquisitions entered...more

Wiley Rein LLP

Court Declines to Recognize Scrivener’s Errors in D&O Policy’s Capacity Exclusion

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The United States District Court for the Southern District of New York, applying Georgia law, has declined to recognize certain punctuation and spacing errors in the capacity exclusion of a directors and officers liability...more

Wiley Rein LLP

Derivative Exception to Insured v. Insured Exclusion Applies Only to Derivative Suits Brought by Non-Insureds

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An Oklahoma federal court has held that a derivative exception to an Insured v. Insured (IvI) exclusion applied only to derivative lawsuits brought by non-insureds, and did not save coverage for a direct claim filed by an...more

Farella Braun + Martel LLP

In Verizon Decision Careful Review of Insurance Policies Expands Coverage

In Verizon Communications Inc. v. National Union Fire Insurance Co. of Pittsburgh, Pa. the Delaware Superior Court ruled that Verizon was entitled to a defense under its D&O policy for fraudulent transfer claims. Although the...more

Wiley Rein LLP

Delaware Supreme Court Applies Delaware Law in D&O Coverage Dispute Involving California Company Incorporated in Delaware

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In a much-watched case, the Delaware Supreme Court has held that Delaware law governs a dispute regarding insurance coverage for a federal securities class action under D&O policies issued in California to a California...more

Farella Braun + Martel LLP

“Unfair Trade Practices” Exclusion Does Not Extend to Consumer Protection Claims

Two phrases combined in a single exclusion—“alleging, arising out of, based upon or attributable to any violation of any law…” and “as respects… unfair trade practices” could inspire carriers to make trouble for policyholders...more

Wiley Rein LLP

Excess E&O Insurer Must Reimburse Defense Expenses Pending Resolution of Insured’s Coverage Dispute with Primary D&O Insurer

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The United States District Court for the District of Kansas, applying Kansas law, has held that an excess E&O insurer was required to advance defense costs where coverage under a potentially responsive D&O policy had not yet...more

Bowditch & Dewey

Extending Liability Coverage By Providing Notice of Circumstances

Bowditch & Dewey on

Litigation concerning COVID-19 has already begun. A number of lawsuits have been filed against cruise lines alleging that they were negligent by operating with infected passengers and crew members and failing to screen...more

Carlton Fields

Look No Further Than the Insuring Clause: Ill-Gotten Gains Do Not Constitute Covered “Loss”

Carlton Fields on

On August 26, 2019, the Eleventh Circuit Court of Appeals, applying Florida Law, held that ill-gotten gains do not constitute covered “loss” within the meaning of a D&O policy. In Philadelphia Indemnity Insurance Co. v. Sabal...more

Pillsbury - Policyholder Pulse blog

Delaware Court Adopts Pillsbury Theory that Shareholder Appraisal Actions Are Covered Securities Claims Under D&O Policies

Pillsbury secured an important victory for its client, Solera Holdings Inc., when Delaware Superior Court Judge Abigail LeGrow held—in a matter of first impression anywhere in the country—that a shareholder appraisal action...more

Carlton Fields

Beware Of The Warranty – Second Circuit Relies On Terms Of Warranty, Not Policy, To Make Coverage Determination

Carlton Fields on

Can the terms of a warranty impact the scope of coverage provided by an insurance policy even if the policy does not explicitly incorporate the terms of the warranty? The answer to this question appears to be yes, at least...more

Carlton Fields

Who is an Insured and What is a Claim? Circuit Courts Offer Guidance in Applying the “Insured vs. Insured” Exclusion in D&O...

Carlton Fields on

Typical directors and officers (“D&O”) liability policies exclude from coverage claims brought by one of the company’s directors or officers against another, or between the company and any of its directors or officers. The...more

Carlton Fields

Greed is Not Good: The Personal Profit Exclusion

Carlton Fields on

As this blog has frequently discussed, many limitations and exclusions in liability policies address “moral hazard” situations by declining to provide insurance for bad behavior. One such exclusion is the “personal profit...more

Cozen O'Connor

Fifth Circuit Refuses To Predict Texas Will Adopt a Sophisticated Insured Exception to Contra Proferentem

Cozen O'Connor on

Texas has yet to address whether it recognizes a sophisticated insured exception to the doctrine of contra proferentem, and the state’s federal Court of Appeals declined an opportunity to make a prediction about that question...more

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