News & Analysis as of

Policy Terms Commercial General Liability Policies Duty to Defend

Cozen O'Connor

Claims Notes: September 2024

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Litigation arose over whether a suit for misrepresentation and breach of contract arising out of an easement triggered a Commercial General Liability (CGL) insurer's duty to defend. Internal confidential communications...more

Robinson+Cole Construction Law Zone

Water Alone is Not Property Damage Under a CGL Policy in Connecticut

The Connecticut Appellate Court recently provided guidance on what does not constitute property damage under a typical contractor’s Commercial General Liability (CGL) insurance policy in Westchester Modular Homes of Fairfield...more

Carlton Fields

New York Federal Court Enforces “Third Party or Contracted Security” Exclusion to Abrogate Duty to Defend for All Defendants in...

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In Clear Blue Specialty Insurance Co. v. TFS NY Inc., the U.S. District Court for the Eastern District of New York, interpreting the plain and unambiguous terms of a commercial general liability policy issued by Clear Blue...more

Carlton Fields

No CGL Coverage for Opioid Distributor Sued for Economic Damages but Not Bodily Injury Damage

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In Westfield National Insurance Co. v. Quest Pharmaceuticals, the Sixth Circuit held that two insurers owed no coverage obligations to Quest Pharmaceuticals in connection with 77 lawsuits filed against it alleging misconduct...more

Carlton Fields

New York Federal Judge Finds No Duty to Defend Based on War Exclusion’s Insurrection Clause

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In Hartford Fire Ins. Co. v. The Western Union Co. et al., No. 22-CV-0557 (JMF) (S.D.N.Y. Sept. 22, 2022), a federal judge in New York granted Hartford Fire Insurance Company’s motion for judgment on the pleadings and motion...more

Miller Nash LLP

Third Circuit Finds That Allegation of False Comparative Advertising Triggers Duty To Defend

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Most commercial liability policies provide what is known as “personal and advertising injury” coverage, which usually provides coverage for claims that an insured’s advertising defamed or disparaged another person’s or...more

Cozen O'Connor

Fifth Circuit Finds Potential Coverage for Data Breach; Interprets “Publication” Broadly

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Using general contract interpretation principles, the Fifth Circuit reversed summary judgment in favor of an insurer and found a duty to defend Landry’s in a data breach lawsuit. Landry’s Inc. v. The Insurance Company of the...more

Foley Hoag LLP

Obligations of Insurer and Policyholder E-book

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The liability insurance relationship is primarily one of contract, with the insurance policy as the principal source of the parties’ obligations. As with other types of insurance, the duties of the parties—and the...more

Cozen O'Connor

When 1% Equals 100%: New York Rejects Fault Based Approach to Additional Insured Coverage

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When a named insured is only 1% responsible for an accident, what percentage of indemnity coverage is owed to an additional insured? A recent New York federal court says 100%. In New York, additional insured coverage may very...more

Cozen O'Connor

Eleventh Circuit Reaffirms Exception to the ‘Four Corners’ Rule for Determining an Insurer’s Duty to Defend

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As a general rule, an insurer’s duty to defend arises under Florida law when the allegations of the complaint against the insured “fairly and potentially bring the suit within policy coverage.” Jones v. Fla. Ins. Guar. Ass’n,...more

Butler Weihmuller Katz Craig LLP

In South Carolina, Documents Outside the Pleadings May Be Utilized to Exclude Coverage

October 27, 2020 - In third party coverage matters, the traditional test to determine whether an insured is entitled to a defense under a commercial general liability policy is the Comparison or Four-Corners Test....more

Wiley Rein LLP

Insurer Waived Right to Assert Policy Exclusion First Raised in Answer to Declaratory Judgment Complaint

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The U.S. District Court for the Southern District of New York, applying New York law, has concluded that an insurer waived the right to assert a policy exclusion as a coverage defense in a declaratory judgment action after...more

Carlton Fields

Iowa Supreme Court Finds Fatality Allegedly Caused by Gross Negligence Was a Potential “Accident” Under CGL Policy

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Coverage under most commercial general liability (CGL) policies applies only to liability arising from an “accident.” As such, injury or damage that an insured “expected or intended” to occur is not covered....more

White and Williams LLP

CGL Coverage and Coronavirus: Is Causing Exposure an “Occurrence”?

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There is only one thing that can be said for sure about the extent of consequences — human and economic — of the new coronavirus outbreak. Nobody knows. But, as things stand now, minor, and even moderate, have left the barn. ...more

Bradley Arant Boult Cummings LLP

Fifth Circuit Decision Excluding Coverage under Pollution Exclusion for Damage to Stream Caused by Rock Fines

In a sweeping decision, the U.S. Court of Appeals for the Fifth Circuit extended the absolute pollution exclusion to the unplanned discharge of “rock fines,” pellets produced during quarry operations, and denied coverage for...more

White and Williams LLP

Pennsylvania Federal Court Holds Insurer Can’t Use Insured’s Admission to Withdraw Defense

It has long been the rule, under Pennsylvania law, that an insurer's duty to defend is determined "solely" by the allegations in the "four corners" of the complaint against the insured. Kvaerner Metals Div. of Kvaerner U.S.,...more

Pillsbury Winthrop Shaw Pittman LLP

How Far Does Your Sexual Abuse Liability Coverage Extend?

If faced with continuous injury claims based on past acts of sexual abuse, will an insured’s general liability policies with sexual abuse coverage defend? Purchase insurance that is carefully focused on the risks your...more

Troutman Pepper

Federal Court in North Carolina Enforces Insurers’ Duty to Defend a General Contractor as an Additional Named Insured Under the...

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Westfield Ins. Co. v. Weaver Cooke Constr., LLC, 2019 BL 129431 (E.D.N.C. Apr. 11, 2019) - This case arises out of the alleged defective construction of a condominium complex in North Carolina. In 2009, the developer on...more

Carlton Fields

California Federal Court Holds Scope of Duty to Defend Is Determined by the Language of the Contract

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In Harper Construction Co. v. National Union Fire Insurance Co. of Pittsburgh, the Southern District of California rejected an insured’s attempt to expand a CGL policy’s definition of “suit” to encompass mere demands without...more

Troutman Pepper

Boring Through The Details: U.S. District Court Declares Boring Company Dispute Not Covered by Insurance Policies

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Maxum Indemnity Co. v. Robbins Co., P.C., No. 1:17-CV-01968, 2018 U.S. Dist. LEXIS 57729 (N.D. Ohio Mar. 28, 2018) - On March 21, 2018, the United States District Court for the Northern District of Ohio granted a motion...more

Carlton Fields

Failure To Procure Cyber Insurance Could Haunt Your Company

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A federal court in Florida recently adopted the now well-developed consensus that data breach losses are not covered under standard Commercial General Liability (CGL) policies....more

Carlton Fields

Eleventh Circuit Finds Exclusion Bars Trademark Infringement And Dependent False Designation And Unfair Competition Claims

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Duty to defend principles are generally well-settled in most jurisdictions: If the allegations in an underlying complaint potentially fall within the scope of coverage, the insurer must defend. ...more

Carlton Fields

To Defend Or Not To Defend? Northern District Of Ohio Provides Guidance For Determining Whether To Defend An Arbitration

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While the rules for determining whether a liability insurer has a duty to defend a lawsuit are generally well-known, questions can arise when an insurer is asked to defend an arbitration....more

White and Williams LLP

Insurers May Consider Extrinsic Evidence “Irrelevant to the Principal Merits” in Evaluating the Duty to Defend

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For third-party liability insurers, no single phrase is more paramount (and vexing) than “the duty to defend is broader than the duty to indemnify.” The duty to defend is one of the most fundamental concepts in insurance...more

Rumberger | Kirk

Chapter 558 Pre-Suit Notice May Trigger an Insurer's Duty to Defend and Indemnify

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The Supreme Court of Florida recently issued an opinion in Altman Contractors, Inc. v. Crum & Forster Specialty Ins. Co., No. SC16-1420, 2017 WL 6379535 (Fla. Dec. 14, 2017), which impacts an insurer’s duty to defend and...more

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