News & Analysis as of

Denial of Insurance Coverage Summary Judgment

Zelle  LLP

Calif. Smoke Claim Ruling Gives Insurers Support On Denials

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In their recent Law360 guest article titled "Reconciling 2 Smoke Coverage Cases From California," the authors described a California appellate court's Feb. 7 opinion in Gharibian v. Wawanesa General Insurance Co. as an...more

Carlton Fields

Divided Ninth Circuit Finds Claimant’s Failure to Provide Medical Records Insulates Insurer From Bad Faith Failure to Settle

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If at first you don’t succeed, try, try again. An age-old adage that now provides critical guidance for insurers seeking to protect themselves in the face of bad faith failure to settle claims....more

Rivkin Radler LLP

April 2025 New York Insurance Coverage Law Update

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John H. Fisher and his P.C. represented a client in a medical malpractice action filed on February 15, 2019, alleging that the defendant medical providers failed to provide proper prenatal care to the client, causing the...more

Carlton Fields

Eighth Circuit Finds No Coverage Under “Ensuing Loss” Provision Under Arkansas Law

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“Ensuing loss” provisions have long been the subject of nuanced arguments in insurance litigation. The provisions, which sometimes afford coverage for a “covered loss” stemming from an expressly excluded peril, serve as...more

Wiley Rein LLP

Notice Prejudice Rule Applies to Claim Not Reported “As Soon As Practicable” But Within Policy Period

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The United States District Court for the District of Kansas, applying Kansas law, has held that an insurer must show prejudice to deny coverage when an insured provided notice of a claim within the policy’s three-year policy...more

Wiley Rein LLP

No Coverage for Lawsuit Where “Claim” First Made at Time of Pre-Inception Tolling Agreement

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In a win for Wiley’s client, a New York intermediate appellate court, applying New York law, has affirmed that no coverage is available for a legal malpractice lawsuit because the “claim” was first made before the policy’s...more

Marshall Dennehey

Third District Court of Appeal Rules Affidavit Lacks Evidence Linking Damage to Tropical Storm Eta

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Thomas A. Bouchard, Jr. v. Citizens Prop. Ins. Corp., Fla. 3d DCA, No. 3D12-2202, February 19, 2025 - Thomas Bouchard, the appellant, appealed a final summary judgment order entered in favor of Citizens Property Insurance...more

Marshall Dennehey

Fourth District Court of Appeal: Noncompliance with Post-Loss Requirements Is a Contract Breach, No Prejudice to Insurer Needed

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Alton Forbes v. People’s Trust Ins. Co., Fla. 4th DCA, No. 4D2023-2375, January 8, 2025 - The Fourth District Court of Appeals ruled that the final judgment against the appellant stands because the appellant failed to comply...more

Rivkin Radler LLP

March 2025 New York Insurance Coverage Law Update

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The owners of a warehouse leased it to a commercial tenant to operate a photography studio. The lease required the tenant to procure insurance for the owners and to indemnify them for the negligent acts of the tenant’s...more

Marshall Dennehey

Court Reverses Summary Judgment, Finding Insurer Failed to Prove Policy Exclusion

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Ronald and Lovelie Belizaire v. Citizens Prop. Ins. Corp., Fla. 4th DCA, No. 4D2023-2488, February 12, 2025 - The Fourth District Court of Appeal reversed the trial court’s order granting summary judgment in favor of the...more

Maynard Nexsen

Lessons in Limitation – Contractual Limitations Provisions as a Basis for Summary Judgment

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In recent weeks, our firm obtained summary judgment under a contractual limitations provision that the plaintiff-insured argued had been equitably tolled due to the insurance carrier’s conduct. Although the good guys won, the...more

Carlton Fields

A Bridge Too Far: Pennsylvania Federal Court Declines to Extend Coverage Beyond Policy’s Plain and Unambiguous Terms

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It’s apt to name a blog post after one of history’s great action movies when the case involves a “conceptual artillery duel” that “ends in a draw,” and that is exactly how U.S. District Judge Gerald Austin McHugh Jr. of the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Ninth Circuit Affirms ERISA Plan Administrator’s Decision, Validates Use of Industry Guidelines and Medical Evidence

On March 5, 2019, Magistrate Judge Joseph C. Spero of the U.S. District Court for the Northern District of California issued his opinion in Wit v. United Behavioral Health, in which he attempted to significantly change how...more

Cozen O'Connor

Jackson v. Spinnaker: Court Rules a Thorough Investigation is Just Good Business, Not Bad Faith

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In Jackson v. Spinnaker Insurance Company, the United States District Court for the Western District of Pennsylvania considered a homeowners insurance coverage dispute, ultimately finding that questions of residency and...more

Marshall Dennehey

Statute of Limitations Stands: Pennsylvania Superior Court Affirms Dismissal of Breach of Contract Claim Against Insurance Broker

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The Pennsylvania Superior Court recently affirmed the Philadelphia County Court of Common Pleas’ dismissal of breach of contract claims asserted against an insurance broker in Thuong Erin Wasielewski, Individually and as...more

Segal McCambridge

New York Appellate Court Clarifies Insurer Obligations Under the Child Victims Act

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The New York Appellate Division Fourth Department recently issued a decision affirming in part and reversing in part summary judgment motions against GuideOne Mutual Insurance Company (“GuideOne”) in a case brought by The...more

Cozen O'Connor

The Importance of Experts J&S Welding, Inc. v. Liberty Mutual Insurance Company

Cozen O'Connor on

In J&S Welding, Inc. v. Liberty Mutual Insurance Company, the U.S. Court of Appeals reviewed a summary judgment ruling in favor of co-defendant West American Insurance Company (“West American”), issued by the U.S. District...more

Wiley Rein LLP

Washington Court Holds Late Notice Bars Coverage Under Claims-Made Policy

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A federal district court, applying Washington law, has held that coverage for a claim was barred because an insured failed to provide notice within the claim-made policy’s reporting deadline. In November 2017, the insured...more

Butler Weihmuller Katz Craig LLP

Federal Court Applying Alabama Law Finds That Insurer Has No Duty To Defend Failure-to-disclose Action

The duties to defend and indemnify arise out of an insurer’s contract with its insured. It is a commonly accepted principle under Alabama law that an insurer’s duties to defend and indemnify are separate and distinct. Indeed,...more

Wiley Rein LLP

Insurer Must Show Prejudice to Deny Coverage for Untimely Notice Under Claims-Made Policy

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The United States District Court for the Central District of California, applying California law, has held that an insurer must show prejudice to deny coverage for untimely notice under a claims-made policy....more

Rivkin Radler LLP

New York Insurance Coverage Law Update - February 28, 2023

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Court Holds That Insurer Was Not Volunteer And May Seek Subrogation From Other Insurer But That Other Insurer’s Policy Is Excess- Walter Breitenbach, who was insured by Adirondack Insurance, struck a pedestrian with his...more

Rivkin Radler LLP

New York Insurance Coverage Law Update - January 30 2023

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Southern District Refuses To Use Extrinsic Evidence “Bound Up With Merits” Of Underlying Action To Defeat Duty To Defend- 622 Third Avenue LLC filed a declaratory judgment action against Harleysville Worcester Insurance...more

Wiley Rein LLP

Revising Prior Order, Georgia Court Holds Two EEOC Charges and Resulting Lawsuit by the Same Claimant Are All Claims “Made or...

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The United States District Court for the Northern District of Georgia, applying Georgia law and revising its prior summary judgment order, has held that a restaurant is not entitled to coverage under a...more

Wiley Rein LLP

Lawyers Professional Liability Policy Does Not Cover Non-Insured Construction Management Company; Insurer Justified in Requesting...

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A New York federal court, applying New York law, has held that a lawyers professional liability policy does not provide coverage to a construction management company not named as an “insured” in the policy and that did not...more

Cozen O'Connor

Pennsylvania District Court Holds Materiality Does Not Require Fraud

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A District Court in the Eastern District of Pennsylvania recently held that an insured’s submission of  invoices altered to inflate replacement costs for water-damaged inventory constituted material misrepresentations. ...more

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