News & Analysis as of

Property Damage Summary Judgment Insurance Industry

Cozen O'Connor

Insurer’s Use of Conflicting Reports Not Bad Faith, Says Court

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In El Dueno, LLC v. Mid-Century Insurance Company (2025 WL 1540329) (10th Cir. 2025)), the Tenth Circuit Court of Appeals affirmed summary judgement on behalf of the insurer on the basis that the insurer did not act in bad...more

Zelle  LLP

Calif. Smoke Claim Ruling Gives Insurers Support On Denials

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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

Zelle  LLP

Concurrent Causation is Key – Fifth Circuit Holds Insured to its Causative Burden

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The United States Fifth Circuit Court of Appeals recently affirmed summary judgment granted by the bankruptcy court in favor of commercial property insurer in a Winter Storm Uri claim, holding that the insured motel owners...more

Zelle  LLP

Any is Not All and The Future is Not Now: The Contours of the Cosmetic Damage Exclusion Taking Shape

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In Iyengar v. Liberty Insurance Corporation, No. SA-21-CV-1091-FB, 2024 WL 5505300 (W.D. Tex. Dec. 13, 2024), District Judge Biery denied Plaintiffs’ Motion for Clarification regarding Magistrate Judge Bemporad’s...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

Zelle  LLP

Federal Court Correctly Concludes that a Simple Disagreement Between Experts Does Not Support a Claim for the Breach of the Duty...

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U.S. District Court Xavier Rodriguez of the United States District Court for the Western District of Texas recently issued a decision granting summary judgment for an insurance carrier in a first-party case involving alleged...more

Zelle  LLP

Federal Court Properly Applies Concurrent Causation and Rejects an “Expert” Opinion –Thompson v. State Farm Lloyds

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U.S. Magistrate Judge Andrew Edison of the United States District Court for the Southern District of Texas recently issued a decision granting summary judgment for an insurance carrier in a first-party case involving alleged...more

Rivkin Radler LLP

August 2024 New York Insurance Coverage Law Update

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Merchants Preferred Insurance Company filed a declaratory judgment action in New York seeking a declaration that it had no duty to defend or to indemnify its insureds in an underlying Florida personal injury action arising...more

Cozen O'Connor

The End of a "Forever War"?: Texas Supreme Court Answers Certified Question Concerning Appraisal

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In Rodriguez v. Safeco Ins. Co. of Ind. the Texas Supreme Court addressed a key issue concerning appraisal that was dividing lower Texas state courts and Texas federal district courts. The United States Court of Appeal for...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Construction-Related Property Damage/Insurance Coverage: Federal Appellate Court Addresses Silica Dust Exclusion

The United States Court of Appeals for the Eighth Circuit (“Eighth Circuit”) addressed in a May 18th Opinion whether an insurance policy addressed certain alleged dust-related property damage. See Grinnell Mutual Reinsurance...more

Rivkin Radler LLP

Insurance Update - March 2021

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In our March Insurance Update, we discuss four state supreme court cases and four cybercrime cases. The state high courts address: •From whose perspective should a consent-to-settle provision be judged? •What standard...more

Rivkin Radler LLP

New York Insurance Coverage Law Update - January 2021

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Southern District Of New York Holds That Insured Not Entitled to Coverage For Losses Resulting From COVID-19- Sparks Steakhouse in New York City filed a coverage action against its insurer, Admiral Indemnity, alleging that...more

White and Williams LLP

The Complex Insurance Coverage Reporter – December 2020

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With the COVID-19 pandemic and government stay-at-home orders came an unprecedented number of claims for business interruption coverage under first-party property policies—and the inevitable coverage litigation over those...more

Carlton Fields

Fifth Circuit Holds That Ensuing Loss Provision of Builders’ Risk Policy Requires Two Separate Events to Qualify for the...

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In Balfour Beatty Construction, LLC v. Liberty Mutual Fire Insurance Company, No. 19-20216 (August 3, 2020), the Fifth Circuit determined that Liberty Mutual’s policy does not cover a construction company’s claim for window...more

Carlton Fields

Coverage Claim Bites the Dust: Seventh Circuit Finds No Coverage for $50 Million Judgment Resulting From Dust Pollution Due to...

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In Greene v. Westfield Insurance Co., the Seventh Circuit Court of Appeals recently affirmed summary judgment finding that commercial general liability policies issued by Westfield Insurance Co. did not cover a $50.56 million...more

Maynard Nexsen

Insurer Defeats Business Interruption Claim on Property Insurance Policy and Accompanying Bad Faith Claim in Federal Court in...

Maynard Nexsen on

A Raleigh jewelry store recently lost its bid to prove coverage, bad faith and punitive damages in a classic case of seemingly strong evidence but actually nothing-burger evidence. In Michael Borovsky Goldsmith, LLC v....more

Butler Weihmuller Katz Craig LLP

Court Finds AIA Subrogation Waiver Inapplicable; Appeal Pending

In Liberty Mutual Fire Insurance Co. v. Fowlkes Plumbing LLC, 17-cv-010-GHD-DAS, 2018 WL 842169 (N.D. Miss. Feb. 12, 2018), the District Court for the Northern District of Mississippi held that the subrogation waiver of...more

Butler Weihmuller Katz Craig LLP

The Eleventh Circuit Strengthens the Third District Court of Appeal's Decision in Cheetham: Know Thy Policy Terms

In Cameron v. Scottsdale Insurance Company, No. 17-11907, 2018 WL 1791889, at *1 (11th Cir. Apr. 16, 2018), the Eleventh Circuit vacated the lower court’s grant of summary judgment in favor of the insurer and relied on...more

Robinson+Cole Property Insurance Coverage...

The Protective Safeguards—Heat Maintained Endorsement Means What it Says: Eastern District of New York Grants Summary Judgment...

Typical first party property policies include provisions that address failure to maintain heat as excluded losses. The Eastern District of New York recently analyzed a specific endorsement requiring that heat be maintained at...more

Cozen O'Connor

Flood Exclusion Unambiguously Excludes Coverage For $49.5M In Hurricane Sandy Losses Caused By Storm Surge

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Cozen O’Connor attorneys Thomas McKay III, Richard Mackowsky, Charles Jesuit, and Melissa Brill recently secured summary judgment from the United States District Court for the Eastern District of New York in favor of Great...more

Robinson+Cole Property Insurance Coverage...

Unequivocal Denial: District of New Jersey Court Outlines What is Not Necessary

We have previously featured New Jersey District Court decisions addressing “unequivocal” denials in the context of policies’ suit limitation provisions. In the latest, Ryan v. Liberty Mut. Fire Ins. Co., No. 14-6308...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...

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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

Haight Brown & Bonesteel LLP

Repeated Use of Defective Fireplace Triggers Duty to Defend Even if Active Fire Does Not Break Out Until After End of Policy...

In Tidwell Enterprises v. Financial Pacific Ins. Co. (No. C078665, filed 11/29/16), a California appeals court held that that even though a house fire occurred after the policy period, there was nonetheless a possibility of...more

Zelle  LLP

Texas Says ‘No Way’ to One Way’s Hail Damage Claim

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In a recent opinion, U.S. District Judge Sidney Fitzwater delivered the final blow to One Way Investments Inc. in its hail damage lawsuit against property insurer Century Surety Company — granting summary judgment in favor of...more

Carlton Fields

Postdiluvian Perils: Second Circuit Weighs Coverage For Losses Suffered After The Waters Recede

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As this blog has reported, exclusions and limits for flood coverage have generally held up against the tide of claims arising from Superstorm Sandy. Now that the water is gone, however, new losses have been discovered, and...more

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