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Negligence Co-Insured Issues

White and Williams LLP

Wyoming Supreme Court Picks a Side After Reviewing the Sutton Rule

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In a matter of first impression, the Supreme Court of Wyoming (Supreme Court), in West American Insurance Company v. Black Dog Consulting Inc., No. S-23-0052, 2023 WY 109, 2023 Wyo. LEXIS 111, examined whether a landlord’s...more

White and Williams LLP

New Hampshire Applies Crete/Sutton Doctrine to Bar Subrogation Against College Dormitory Residents

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Pursuant to the Sutton Doctrine, first announced in Sutton v. Jondahl, 532 P.2d 478 (Okla. Ct. App. 1975), some jurisdictions consider a tenant a coinsured of its landlord absent an express agreement to the contrary. In Ro v....more

Butler Weihmuller Katz Craig LLP

New Hampshire Confirms Sutton Doctrine Applies To College Dormitories

The determination of whether a tenant is also a coinsured under the landlord’s policy ultimately comes down to the language in the lease and relationship between the parties. In the absence of specific language or a unique...more

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