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Occurrence

Carlton Fields

Ohio Federal Court Says Human Trafficking Claims Can Be Covered “Occurrences” Under CGL Policy

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Hotels across the country in the past decade have experienced a wave of litigation under the Trafficking Victims Protection Reauthorization Act (TVPRA). The law provides victims of certain human trafficking crimes with a...more

Rivkin Radler LLP

April 2026 Insurance Update

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Our April update highlights some of the insurance questions courts were asked to decide this past month. We all know about the broad duty to defend that applies to many primary liability policies. But does that same rule...more

Wiley Rein LLP

Illinois Federal Court Holds CGL Policy Does Not Cover Remediation Costs for Illegal Dumping

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The U.S. District Court for the Central District of Illinois, applying Illinois law, held that a commercial general liability policy did not provide coverage for a suit seeking compensation for costs associated with...more

Carlton Fields

No Accident, No Duty to Defend: Meta Loses Defense Coverage for Social Media Child Harm Lawsuits

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In Hartford Casualty Insurance Co. v. Instagram LLC, the Delaware Superior Court granted the insurers’ motion for partial summary judgment, finding that various primary and excess general liability insurers had no duty to...more

White and Williams LLP

Top Developments 2026 - Issue 1

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Ohio Supreme Court clarifies that attorney-client privileged communications in an insurer’s claim file are discoverable only upon a prima facie showing of “bad faith” and a determination by the trial court, following an...more

Zelle  LLP

4th Circ. D&O Ruling Shows Why Textual Policy Args Are Best

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In litigated claims, courts can lose their footing when it comes to determining the number of claims or occurrences at issue. The stakes are high. If there are multiple claims or occurrences, it could multiply available...more

Husch Blackwell LLP

Navigating the Reinsurance Landscape of Social Media Addiction Litigation

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The ongoing bellwether trial in California has brought renewed attention to an unprecedented wave of lawsuits targeting social media companies. These actions allege that major platforms are intentionally engineered to foster...more

Marshall Dennehey

Delaware Superior Court Addresses Continuous Representation Doctrine in Legal Malpractice Case—But Was It Really Applied?

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K. Dyton v. A. Ahern, 2025 WL 3232911 (Del. Super. Ct. Nov. 19, 2025), re-argument denied, 2025 WL 3496991 (Del. Super. Ct. Dec. 5, 2025) - In what the court stated was a matter of first impression, the Delaware Superior...more

Rivkin Radler LLP

December 2025 Insurance Update

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We begin this month’s update with a pair of cases from the Eleventh Circuit, which unfortunately, both involve claims arising from senseless shootings. The court first takes up the issue of number of occurrences in the...more

Butler Weihmuller Katz Craig LLP

Decoding the Number of “Occurrences”: Florida’s Insurance Puzzle in Mass-Injury Cases

As the world confronts more mass shootings, these tragic events leave courts continuing to confront their effects on insurance coverage. A federal appeals court in Florida recently addressed the issue of how many...more

Rivkin Radler LLP

November 2025 Insurance Update

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Courts considered some interesting insurance issues this past month. The Indiana Supreme Court lent a sympathetic ear to insurers facing multiple claims against a single policy by adopting a “safe harbor” provision for...more

Freeman Mathis & Gary

Revisiting Koikos: The eleventh circuit re-interprets the word “occurrence”

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In the aftermath of the Parkland school shooting in 2018, victims filed over sixty lawsuits against the Broward County Sheriff’s Office (“BCSO”) for failing to secure Marjory Stoneman Douglas High School. The BCSO tendered...more

Wiley Rein LLP

No Coverage for Failure to Warn of TCE Contamination Plume

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The Missouri Court of Appeals, applying Missouri law, held that insurers had no duty to defend or indemnify a defense contractor in connection with a class action alleging failure to warn of groundwater contamination. Certain...more

Zelle  LLP

Corrosion Exclusions - Differences Across the Atlantic

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Corrosion exclusions are not interpreted in the same manner on both sides of the Atlantic Ocean. Generally speaking, in the U.K., corrosion exclusions only apply to exclude the claim where the corrosion event was a gradual...more

Sheppard

Intentional Conduct and Negligence are not Mutually Exclusive; The Concurrent Cause Doctrine Applies Only When Each Independent...

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When it comes to liability insurance, the distinction between intentional acts and negligence can have major implications for coverage—especially in cases involving violent conduct. A recent decision from the California Court...more

Rivkin Radler LLP

September 2025 Insurance Update

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Jealous husbands, protection payments, defective earplugs, opioids, and abuse of process form the backdrop to our September Insurance Update. We begin with two cases from Delaware’s high court. The first reaffirms...more

White and Williams LLP

Top Developments: 2025 - Issue 3

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Kane v. Syndicate 2623-623 Lloyd’s of London, 2025 N.M. App. LEXIS 38 (N.M. Ct. App. June 16, 2025) - New Mexico appeals court holds that the language of a cyber insurance policy providing liability coverage “for” a...more

Rivkin Radler LLP

August 2025 Insurance Update

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“Arising out of” is a phrase commonly found in an insurance policy. It’s a broad phrase, and courts construe it that way. When this phrase appears in an exclusion, courts often apply a “but for” causation test. And that may...more

Wiley Rein LLP

Colorado Court of Appeals Permits COVID-19 Coverage Suit to Proceed Based on Health Care Endorsement Coverage

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The Colorado Court of Appeals (Division VI), applying Colorado law, partially affirmed a trial court decision dismissing an action seeking insurance coverage for COVID‑19 related losses. Spectrum Retirement Communities, LLC...more

Rivkin Radler LLP

June 2025 Insurance Update

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We’ve selected five recent insurance decisions for this month’s update. Foreign insurers will be pleased with the Second Circuit’s revamped view of the New York Convention. In finding that the international treaty is...more

Stoel Rives LLP

Oregon Supreme Court Expands CGL Coverage for Construction Defects: Twigg v. Admiral Insurance Company

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Businesses and homeowners in Oregon often assume their insurance will cover a contractor’s faulty work. That assumption was put to the test in Twigg v. Admiral Insurance Co., 373 Or. 475 (2025), an Oregon Supreme Court...more

Zelle  LLP

“Occurrence” Provisions Within Excess Policies Support an Exposure Trigger Theory Application for Asbestos-Related Claims

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Asbestos fibers, chemical fumes, environmental pollutants—what do they have in common? They all involve injuries that manifest over time and are continuously at the center of the complex exposure trigger debate....more

Melito & Adolfsen

“Taking the Suddenness Out of Accident”

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Can AI or Chat GBT write poetry, perhaps by accident. But an insurance underwriter came up with the phrase: “Taking the suddenness out of accident.” Now that’s poetry. The poet was describing the “occurrence” definition in an...more

Houston Harbaugh, P.C.

Insurers Not Required to Cover Climate Change Litigation

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In a significant ruling, the Hawaii Supreme Court has determined that AIG is not required to provide coverage for a lawsuit against Sunoco subsidiary, Aloha Petroleum. The Hawaii court found a pollution exclusion in AIG’s...more

Hinshaw & Culbertson - Insights for Insurers

The Hawaii Supreme Court Determines that Greenhouse Gases are "Pollutants" and Ruled Coverage for Climate-Related Claims is Barred...

On October 7, 2024, the Hawaii Supreme Court, responding to questions certified by the United States District Court for the District of Hawaii, determined that insurers had no duty to defend Aloha Petroleum ("Aloha") in two...more

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