News & Analysis as of

Denial of Insurance Coverage Summary Judgment Appeals

Zelle  LLP

Calif. Smoke Claim Ruling Gives Insurers Support On Denials

Zelle LLP on

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

Carlton Fields on

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

Carlton Fields

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

Carlton Fields on

“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

Marshall Dennehey

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

Marshall Dennehey on

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

Marshall Dennehey on

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

Rivkin Radler LLP on

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

Marshall Dennehey on

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

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

Hinshaw & Culbertson LLP

The LHD/ERISA Advisor - October 2020: Tenth Circuit Finds District Court Applied Wrong Standard of Review in Evaluating Plan...

Hinshaw & Culbertson LLP on

In Lyn M. v. Premera Blue Cross, 2020 U.S. App. LEXIS 23395 (10th Cir. July 24, 2020), the Tenth Circuit held that a district court had applied the wrong standard of review and incorrectly evaluated an ERISA plan...more

Carlton Fields

The Three “Musts” for a Competent Affidavit or Declaration

Carlton Fields on

Florida’s Second District Court of Appeal recently issued a decision that serves as a reminder not to take for granted a proposition that most practicing attorneys regularly encounter: a motion for summary judgment must be...more

Carlton Fields

Is Your “Securities Claim” Actually Covered Under Your D&O Policy? A Review of In Re Verizon Insurance Coverage Appeals

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The question of what constitutes a “securities claim” in the context of public company D&O policies is often debated in insurance coverage disputes, and the answer to this question can have significant effects on the scope of...more

Carlton Fields

Eleventh Circuit Rejects Insurer-Defended Policyholder’s Bid to Expand Florida’s Bad Faith “Excess Judgment Rule” to Include...

Carlton Fields on

In Cawthorn v. Auto-Owners Insurance Co., No. 18-12067 (11th Cir. Oct. 25, 2019), the Eleventh Circuit affirmed the U.S. District Court for the Middle District of Florida’s grant of summary judgment in favor of Auto-Owners...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

Farella Braun + Martel LLP

3 Lessons For Calif. Insureds From Late-Notice Rule Decision

In Pitzer College v. Indian Harbor Insurance Company, the California Supreme Court resolved two previously open questions in insurance law: (1) it concluded that the notice-prejudice rule is a fundamental public policy of...more

Robins Kaplan LLP

Appeals in Insurance Litigation – Appreciating Standards of Review

Robins Kaplan LLP on

It is said that the first rule of a successful appeal is to win in the trial court. But, regardless of winning or losing in the trial court, one of the most important considerations in evaluating exposure and the likelihood...more

Patton Sullivan Brodehl LLP

Loss of Use can be “Property Damage” under Insurance Policies

General liability insurance policies normally cover “property damage.” Physical injury to, or outright destruction of, property almost always fits within policy coverage. But what about situations when the property is not...more

Farella Braun + Martel LLP

Evicting Tenants Over “Illegal” Cannabis Operation Comes Back to Bite Landlords in Coverage Dispute

A 6th Circuit case decided earlier this year demonstrates how positions taken by insureds in prior litigation can impact or foreclose coverage in subsequent disputes with insurers. See K.V.G. Properties, Inc. v. Westfield...more

Carlton Fields

Clearing The Air: Tenth Circuit Strikes Down An Indoor Air Quality Exclusion, Citing Ambiguity

Carlton Fields on

Ambiguity strikes again. While the heavily litigated pollution exclusion is well-known in the insurance world, its progeny—the indoor air exclusion—only recently has started making its way around the block. ...more

Butler Snow LLP

Contracts May “Legally” Obligate a Party to Pay, Even Without a Court Judgment

Butler Snow LLP on

Time and again, courts have been tasked with construing ambiguous and inconsistent terms in contracts. Recently, the Sixth Circuit revisited the issue of interpreting contractual language in Dark Horse Express, LLC v. Lancer...more

Robinson+Cole Property Insurance Coverage...

What Is Prompt Notice? Second Circuit Analyzes Late Notice In New York

Property insurance policies typically require that, once an insured suffers a loss, the insured report the loss to the insurance carrier promptly. The purpose of such a provision is to allow an insurer to investigate a claim...more

Cozen O'Connor

Coverage to Rebuild a Foundation to Comply with Changed Building Codes Following a Fire are Subject to Code-Upgrade Endorsement’s...

Cozen O'Connor on

Does the efficient proximate cause rule serve to afford coverage for the additional costs to rebuild the foundation of a home in compliance with changed building code requirements beyond the sublimit of liability of an...more

Pullman & Comley, LLC

The Ghost of Systems Past: “Big Data” Suits Loom, But Old Data Issues Remain Unresolved

Pullman & Comley, LLC on

2017 could be big for litigation over “Big Data” applications in insurance. This past year saw the filing of several “price optimization” class actions, and claims against a fraud detection tool, similar to the ones used by...more

Cozen O'Connor

“Context Matters” – Tenth Circuit Holds Mudslide Not an Explosion Under Property Policy

Cozen O'Connor on

On August 29, 2016, the U.S. Court of Appeals for the Tenth Circuit affirmed a Colorado district court ruling that the sudden obliteration of a building in a 2013 mudslide did not constitute an “explosion” under a commercial...more

Cozen O'Connor

Massachusetts Court: Loss of Drink Product Caused By Faulty Workmanship And Design of Bottle Caps Not a Covered Ensuing Loss

Cozen O'Connor on

Monday saw a unanimous panel of Massachusetts’ intermediate level appellate court reject a policyholder’s ensuing loss arguments. In H.P. Hood LLC v. Allianz Global Risks U.S. Ins. Co., 2015 Mass. App. LEXIS 175, 2015 WL...more

Carlton Fields

“Contractor?” I Do Not Think That Employers’ Liability Exclusion Means What You Think It Means

Carlton Fields on

Over the summer, this blog reported on how the Supreme Court of Pennsylvania managed to parse an employer’s liability exclusion to find that it did not exclude claims by employees of additional insureds. As the leaves started...more

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