News & Analysis as of

Occurrence Insurance Litigation

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

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

Cozen O'Connor

Claims Notes: April 2024

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Some jurisdictions consider the ISO-form "bodily injury" definition to be ambiguous as to whether emotional distress requires physical harm to be bodily injury. Many insurers have amended bodily injury to expressly require a...more

Rivkin Radler LLP

New York Insurance Coverage Law Update - February 2024

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The insured, Consolidated Restaurant Operations, a company that owns and operates dozens of restaurants, obtained a commercial property policy from Westport Insurance Company. Subject to certain exclusions, the policy covered...more

BCLP

English Court Decides COVID-19 is a “Catastrophe”

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The English Court has, for the first time, considered the meaning of a “catastrophe”, as well as how Hours Clauses work in the context of non-damage business interruption losses claimed under two Property Catastrophe Excess...more

Rivkin Radler LLP

Insurance Update - January 2024

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In our January insurance update, we include three state cases addressing some less common situations. It’s not often that a pollution exclusion is interpreted in the context of an auto policy. But the South Dakota Supreme...more

Rivkin Radler LLP

Insurance Update - October 23, 2023

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Here’s what we discuss in our October Insurance Update. Illinois: Environmental Suits Alleging Non-Compliance with Laws and Regulations Did Not Assert an “Occurrence”- Massachusetts (federal): Insurer May Consider Sums...more

Carlton Fields

No Paying Over Slow Milk? Wisconsin Appellate Court Finds Intentional Act by Cattle Feed Supplier May Be “Occurrence” Under CGL...

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In Riverback Farms LLC v. Saukville Feed Supplies Inc., a panel of the Wisconsin Court of Appeals found that an intentional act may still constitute an “occurrence” under a commercial general liability policy, reversed the...more

Cozen O'Connor

First Circuit Affirms Insurer’s Denial for Late Notice Under Claims-Made Policy

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On August 9, 2023, the U.S. Court of Appeals for the First Circuit affirmed the holding of the District of Massachusetts that failure to provide notice according to a claims-made policy’s terms and conditions forfeits any...more

Marshall Dennehey

Doubling Down: Two Third Circuit Decisions Reaffirm that Faulty Workmanship Does Not Constitute an “Occurrence” in Pennsylvania

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In two separate decisions handed down last month, the Third Circuit Court of Appeals re-affirmed that, under Pennsylvania law, claims against contractors for faulty workmanship do not constitute an “occurrence” and are...more

Neal, Gerber & Eisenberg LLP

NGE OnDemand: The Importance of Timely Reporting Occurrences, Claims and Suits to Insurers with Paul Walker-Bright

When disaster strikes your business or a lawsuit is filed against you in responding to the crisis, it is easy to overlook the existence of insurance that may reimburse you for the associated expenses and damages. A delay in...more

Carlton Fields

Ninth Circuit Flags NFL Stadium Design and Construction as Intentional Conduct Resulting in Out of Bounds Claim for Occurrence...

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The Ninth Circuit Court of Appeals recently found that insurers did not have to defend a construction company from the San Francisco 49ers’ claim that the company negligently failed to construct the NFL team’s stadium to be...more

Sheppard Mullin Richter & Hampton LLP

Continuous and Progressive Damage Raised Factual Question as to the Timing of “Occurrence”

Thomas Guastello v. AIG Specialty Insurance Company, — Cal.Rptr.3d –, 2021 WL 650878 (Cal. Ct. App., Feb. 19, 2021), Fourth Appellate District Court of Appeal, Case No. G057714. Various stakeholders in the Pointe Monarch...more

White and Williams LLP

The Complex Insurance Coverage Reporter – 2020 Year in Review

Welcome to CICR’s annual review of insurance cases. Here, we spotlight decisions from the last year that you should know about — and a few pending cases to watch. As our picks for “Cases to Know” (below) indicate,...more

Carlton Fields

South Carolina Federal Court Finds No Coverage for Faulty Workmanship Damages Discovered Years After Occurrence-Based Policy...

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Potential Six-Year Delay in Notice of Flood and Mold Damage “Substantially Prejudiced” Insurer - In Atain Specialty Insurance Company v. Carolina Professional Builders, LLC et al., 2:18-cv-2352-BHH (D.S.C. Oct. 2, 2020),...more

Butler Weihmuller Katz Craig LLP

Defining Occurrence – When Policy Definitions Do Not Apply To All Coverages

On September 8, 2020 the United States Court of Appeals for the Eleventh Circuit issued its decision in Port Consolidated, Inc. v. International Insurance Company of Hannover, PLC, 2020 WL 5372281 (11th Cir 2020). The...more

White and Williams LLP

Illinois Appellate Court Clarifies What Is and Is Not an “Occurrence” in the Construction Defect Context

On December 31, 2019, the First District Illinois Appellate Court issued its decision in Owners Insurance Company v. Precision Painting & Decorating Corporation, clarifying what does and does not constitute “property damage”...more

Pillsbury - Policyholder Pulse blog

A Recent “Event” in Wisconsin: Appellate Court Rules That a Commonly Used London Market “Occurrence” Definition Is Ambiguous

In recent years, Wisconsin generally has been a pro-policyholder jurisdiction when it comes to long-tail environmental coverage cases. That trend continues with a decision by a Wisconsin appellate court in a case involving...more

King & Spalding

Insurance Coverage for Active Shooter Incidents After Recent Court Decisions Enforcing Broad Policy Exclusions

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Active shooter incidents[i] are occurring with greater frequency in the United States, resulting in a new type of premises liability exposure for most companies. The broad insuring agreement in CGL policies typically covers,...more

White and Williams LLP

PA Superior Court Provides Clarification on Definition of CGL “Occurrence” When Property Damage Is Caused by Faulty Building...

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The standard for an “occurrence” under a commercial general liability (CGL) insurance policy has been addressed on several occasions by Pennsylvania courts when an insured has allegedly performed faulty workmanship on a...more

Nutter McClennen & Fish LLP

Insurer Prohibited from Relitigating Issue 'Necessarily Determined' by Federal Court

Judge Sanders granted partial summary judgment in favor of Raw Seafoods, Inc. (RSI), a seafood processor, in a coverage dispute with its insurer, Hanover Insurance Group (Hanover). Judge Sanders held that Hanover was bound by...more

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