Insurance Law Alert

January 2015

In This Issue
In Back-to-Back Rulings, Wisconsin Supreme Court Holds That Pollution
Exclusion Bars Coverage for Fertilizer Contamination
The Wisconsin Supreme Court issued two decisions last month holding that a pollution
exclusion unambiguously applied to claims alleging contamination caused by manure-based
fertilizer. Preisler v. Gen. Cas. Ins. Co., 2014 WL 7373070 (Wis. Dec. 30, 2014); Wilson Mut.
Ins. Co. v. Falk, 2014 WL 7375656 (Wis. Dec. 30, 2014). (click here for full article)“SimpsonThacher &Bartlett LLP is the‘go-to firm’ for some of
the largest and mostcomplex insurance andreinsurance coverage
disputes in the US”–Legal 500
US 2014

New York Appellate Court Rules That Dishonest Acts Exclusion Does Not
Bar Coverage for SEC Settlement Payments
A New York appellate court ruled that a Dishonest Acts Exclusion did not bar coverage forsettlement payments made by Bear Stearns to the Securities and Exchange Commission
because guilt had not been established by final adjudication or judgment. J.P. Morgan Sec. Inc.
v. Vigilant Ins. Co., 2015 WL 175512 (N.Y. App. Div. 1st Dep’t Jan. 15, 2015).
(click here for full article)

Eleventh Circuit Rules That “Insured v. Insured” Exclusion is Ambiguousin Context of FDIC Claims
The Eleventh Circuit ruled that an “insured v. insured” exclusion was ambiguous as applied toclaims brought by the Federal Deposit Insurance Corporation as receiver for a defunct bank. St.
Paul Mercury Ins. Co. v. Fed. Deposit Ins. Corp., 2014 WL 7172472 (11th Cir. Dec. 17, 2014).
(click here for full article)

Two Courts Address When a Claim is Made for Purposes of Coverage
Under Claims-Made Policies
A Massachusetts federal district court and the Eighth Circuit both ruled that there was nocoverage under a claims-made policy because the claims at issue were made prior to theinception of the policy periods. BioChemics, Inc. v. Axis Reinsurance Co., 2015 WL 71493 (D.
Mass. Jan. 6, 2015); Philadelphia Consol. Holding Corp. v. LSI-Lowery Sys., Inc., 2015 WL
127368 (8th Cir. Jan. 9, 2015). (click here for full article)


Simpson Thacher & Bartlett LLP

1

Fifth Circuit Affirms That Misappropriation and Unfair Competition
Claims Do Not Allege Personal and Advertising Injury
The Fifth Circuit ruled that a general liability insurer had no duty to defend or indemnify
misappropriation and unfair competition claims against a policyholder. Nationwide Mut. Ins.
Co. v. Gum Tree Prop. Mgmt., L.L.C., 2015 WL 170244 (5th Cir. Jan. 14, 2015).
(click here for full article)

Florida Court Rules That Statutory Violation Exclusion Bars Coverage forConversion ClaimA Florida federal district court ruled that an insurer had no duty to defend a suit alleging
statutory and common law conversion claims because a Violation of Statutes exclusion barred
coverage for both claims. Am. Cas. Co. of Reading, Pa. v. Superior Pharmacy, LLC, No. 8:13cv-622 (M.D. Fla. Jan. 8, 2015). (click here for full article)

Courts Reach Conflicting Conclusions as to Whether an Insurer Waived
Privilege by Putting Advice of Counsel At Issue
In two recent decisions, the Arizona Court of Appeals and the Tenth Circuit reached different
conclusions as to whether an insurer waived attorney-client privilege by putting the advice ofcounsel at issue. Everest Indem. Ins. Co. v. Rea, 2015 WL 195450 (Ariz. Ct. App. Jan. 15, 2015);
Seneca Ins. Co. v. Western Claims, Inc., 2014 WL 724071 (10th Cir. Dec. 22, 2014).
(click here for full article)2

Pollution
Exclusion Alert:

In Back-to-Back Rulings, Wisconsin
Supreme Court Holds That
Pollution Exclusion Bars Coveragefor Fertilizer Contamination
In Preisler v. Gen. Cas. Ins. Co., 2014 WL
7373070 (Wis. Dec. 30, 2014), a septic service
company sought general liability coverage forclaims alleging that its negligent applicationof septic waste for fertilization purposes
harmed a dairy farm. The insurers denied
coverage on the basis of pollution exclusions
that precluded coverage for harm “arising outof the actual, alleged, or threatened discharge,
dispersal, seepage, migration, release or
escape of ‘pollutants.’” The septic company
did not dispute that the septic material was
dispersed onto the farmland, but argued thatthat material was not a “pollutant” because
it had been used as fertilizer. A trial court
disagreed, and ruled in favor of the insurers.
An appellate court and the Wisconsin
Supreme Court affirmed.
The decision is significant in several respects.
First, the Wisconsin Supreme Court ruledthat in construing whether a substance isa pollutant, the court must evaluate thesubstance “at the point it harms the interestsof another” rather than “on an initial eventthat may have involved a beneficial use of
the substance.” The court therefore deemed
it irrelevant that the septic waste had
been applied for fertilization. Second, inconcluding that a reasonable insured would

consider decomposing septage as a pollutant
when it seeps into a water supply, the court
noted that septage handling is regulatedby the Environmental Protection Agency.
As discussed in our December 2013 Alert,
courts disagree as to whether federal or stateclassifications of material should factor into apollution exclusion analysis. Third, the court
distinguished cases in which a harm-causing
substance (such as carbon dioxide) was notdeemed a “pollutant” because it is “universallypresent and generally harmless in all but
the most unusual circumstances.” The court
noted that although individual componentsof septage are common, decomposing septage
can release high levels of nitrates, which
are not considered “generally harmless” or“pervasive.”On the same day, the Wisconsin Supreme
Court employed similar reasoning and issued
a second opinion addressing the pollution
exclusion, holding that it unambiguously
applied to claims alleging well watercontamination caused by the use of cow
manure as fertilizer. Wilson Mut. Ins. Co. v.
Falk, 2014 WL 7375656 (Wis. Dec. 30, 2014).
The court reasoned that although farmers
may consider manure to be a “universallypresent, desirable and generally harmless
substance,” a reasonable insured would
consider manure in a well to be a pollutant.
The court noted that the pollution exclusion
analysis focuses on the occurrence thatcaused property damage–i.e., the seepageof the manure and resultant contaminationof neighboring wells–not on the initial
application of the manure.

D&O Alerts:

New York Appellate Court Rules
That Dishonest Acts Exclusion
Does Not Bar Coverage for SEC
Settlement Payments
Our March 2014 Alert reported on a New York
trial court decision holding that a Dishonest
Acts Exclusion did not bar coverage forsettlement payments made by Bear Stearns
to the Securities and Exchange Commission
because guilt had not been established by
final adjudication or judgment. J.P. Morgan
Sec. Inc. v. Vigilant Ins. Co., 2014 WL 804129(N.Y. Sup. Ct. New York Cnty. Feb. 28, 2014).
This month, an appellate court affirmed theruling. J.P. Morgan Sec. Inc. v. Vigilant Ins.
3

Co., 2015 WL 175512 (N.Y. App. Div. 1st Dep’t
Jan. 15, 2015).
The Dishonest Acts Exclusion at issue
barred coverage for claims arising out of any“deliberate, dishonest, fraudulent or criminal
act or omission,” but only if a “judgment orother final adjudication” in the underlying
case established such guilt. The appellate
court ruled that the exclusion did not apply
where the underlying claims were resolved bysettlement and administrative order, which
are not equivalent to a final adjudication,
notwithstanding the incorporation of certain
adverse “findings” in the order. The appellate
court explained that the settlement did not“establish” Bear Stearns’ guilt, noting thecompany’s refusal to admit guilt and its
express reservation to contest findings inunrelated proceedings. The appellate court
distinguished decisions in which New York
courts ruled that a consent decree establishedthat a policyholder’s payments constituted
uninsurable disgorgement, stating that thepresent case is “strictly concerned with theunrelated issue of whether an exclusion for‘adjudicated’ wrongdoing applies where thepurported ‘adjudication’ is a consent decreeor other settlement agreement entered intoby the insured, with the caveat that it is not
admitting guilt other than for the purposes ofthe settlement.”
However, the appellate court reversed
the portion of the trial court decisionthat dismissed the insurers’ affirmative
defense based on the public policy against
permitting insurance coverage for intentional
wrongdoing. The appellate court ruled that
although the absence of an “adjudication”
precluded application of the Dishonest
Acts exclusion, there is no adjudication
requirement for an affirmative defense basedon public policy grounds. The insurers were
therefore entitled to rely on findings set forthin the settlement order to support a public
policy-based defense.

Eleventh Circuit Rules That
“Insured v. Insured” Exclusion
is Ambiguous in Context of FDIC
ClaimsAs reported in previous Alerts (see Octoberand April 2014 Alerts), courts have issued
conflicting decisions as to whether an“insured v. insured” exclusion in a directors
and officers policy applies to claims broughtby the Federal Deposit Insurance Corporation(“FDIC”) as receiver for a defunct bank. The
Eleventh Circuit recently weighed in on theissue, reversing a Georgia district court andfinding that the exclusion is ambiguous inthis context. St. Paul Mercury Ins. Co. v. Fed.
Deposit Ins. Corp., 2014 WL 7172472 (11thCir. Dec. 17, 2014).
St. Paul sought a declaration that it owed
no duty to indemnify claims brought by the
FDIC as receiver for a closed bank alleging
tortious conduct on the part of the bank’s
former officers. A Georgia district court
granted St. Paul’s summary judgment motion,
finding that the insured v. insured exclusion
unambiguously barred coverage for claims
brought by the FDIC. The district court
reasoned that not applying the exclusion
would have the effect of reading the phrase“on behalf of any Insured” out of the policy
because “[a]side from a derivative action, theonly party that could bring an action on afederally insured bank’s behalf is the FDIC.”In reversing the district court, the Eleventh
Circuit noted that Georgia law sets a “lowthreshold for establishing ambiguity in
an insurance policy.” On this basis, theEleventh Circuit ruled that the exclusion was
susceptible to two reasonable interpretations.
The Eleventh Circuit relied primarily on
the existence of conflicting court decisions
on the issue, finding that “the mostcompelling argument is that courts who
have addressed similarly worded insured v.
insured exclusions have reached different
results.” The court remanded the matterfor consideration of extrinsic evidence todetermine the parties’ intent.
4

Coverage Alerts:

Two Courts Address When a Claimis Made for Purposes of Coverage
Under Claims-Made Policies
Two courts recently addressed the questionof when a claim is first “made” or “filed” forpurposes of coverage under a claims-madepolicy, and both concluded that there wasno coverage because the claims at issue
were made prior to the inception of thepolicy periods.
A Massachusetts federal district court ruledthat an insurer had no duty to defend a
Securities and Exchange Commission (“SEC”)
Enforcement Action and related subpoenas
because the investigation was all part of asingle “claim” that was first made prior to
the issuance of the policy. BioChemics, Inc.
v. Axis Reinsurance Co., 2015 WL 71493 (D.
Mass. Jan. 6, 2015).
In May 2011, the SEC commenced aninvestigation by Formal Order of BioChemics
and its officers. The SEC issued subpoenas.
During this time frame, the company
was insured by Greenwich Insurance
Company. However, beginning November
2011, BioChemics became insured by Axis
Reinsurance. Shortly after the inception of
the Axis policy, the SEC served additional
subpoenas on BioChemics and its officers
under the same SEC matter identification
number and caption as the initial Formal
Order and subpoenas. In December 2012,
the SEC filed an Enforcement Action against
the company and several individuals. Axis
denied coverage, arguing that the entire SEC

investigation constituted a single “claim” thatwas first made in May 2011 and therefore
was outside the scope of policy coverage. The
court agreed.
The Axis policy defined a “claim” to include
any “civil, arbitration, administrative or
regulatory proceeding.” The policy further
provided that all claims “arising from thesame Wrongful Act … and all Interrelated
Wrongful Acts shall be deemed one Claimand such Claim shall be deemed to be firstmade on the earlier date that: (1) any of theClaims is first made against an Insured under
this Policy or any prior policy … .” The court
held these policy provisions, read together,
supported the conclusion that all SEC actions
taken against BioChemics and its officers
over the two-year period were part of a single“claim.” Additionally, the court concluded
that the claim was first made in May 2011
(during the Greenwich policy period) and wastherefore not subject to coverage under the
Axis policy. Notably, the court reached thisconclusion notwithstanding the fact that someof the misrepresentations alleged in the SEC
enforcement complaint took place during the
Axis policy period.
Along similar lines, the Eighth Circuit ruledthat a professional liability insurer owed
no coverage where a claim was deemed“made” during a 2007 policy period, but
was not reported to the insurer until after
the inception of a 2008 policy period.
Philadelphia Consol. Holding Corp. v. LSILowery Sys., Inc., 2015 WL 127368 (8th Cir.
Jan. 9, 2015).
The coverage dispute arose out of troubled
software programs developed and installed5

by LSi and sold to Hodell in 2007. Softwarerelated problems arose immediately
after installation. In March 2007, Hodell
initiated a series of email communications
with LSi expressing dissatisfaction withthe software and threatening legal action.
Email exchanges, including demands forreimbursement and threats of litigation,
continued through July 2007. During
this period, Hodell retained counsel andattempted to resolve the problems. Finally,in November 2008, Hodell sued LSi andothers asserting fraud, breach of contract andnegligence. Shortly thereafter, LSi notified
its professional liablity insurer of the claims.
The insurer denied coverage under successive
2007 and 2008 policies. A Missouri federal
district court upheld the insurer’s denial,finding no coverage under either policy. The
Eighth Circuit affirmed.
The Eighth Circuit ruled that LSi did notgive notice of a claim or potential claim
within the policy period, as required by the2007 policy’s notice provision. The court
also held that there was no coverage underthe 2008 policy, which provided coveragefor “any claim first made against you during
the policy period.” The court concluded thata claim against LSi was first made prior to
the April 2008 policy inception date, findingthat the communications between Hodell
and LSi from March 2007 through mid2008 constituted a claim. In particular, thecourt reasoned that Hodell’s complaints anddemands for remediation and costs, as wellas its threats to seek legal recourse, taken
together, established the existence of a claim,
defined in both policies to include a “demand
for money.” The court noted that even absent
a specific dollar demand, a proposal to reachsettlement to avoid legal action constitutes
a demand for money. Finally, the court
rejected the argument that prejudice must be
established to deny coverage on the basis of
untimely notice, ruling that Missouri law does
not require such a showing under a claimsmade policy.

competition claims against a policyholder.
Nationwide Ins. Co. v. Lexington Relocation
Serv., LLC, 2014 WL 1213805 (N.D. Miss.
Mar. 24, 2014). This month, the Fifth
Circuit affirmed. Nationwide Mut. Ins. Co.
v. Gum Tree Prop. Mgmt., L.L.C., 2015 WL
170244 (5th Cir. Jan. 14, 2015). The Fifth
Circuit held that the use of trade secrets or
confidential business information does notconstitute “disparagement” and that “theright to privacy” referenced in the personal
injury coverage provision does not extend tobusiness organizations. In addition, the Fifth
Circuit rejected the policyholder’s attempt
to invoke Mississippi’s “true facts” exception
with respect to an insurer’s duty to defend.
The policyholder argued that even if theunderlying complaint did not allege facts
within coverage, the insurer was obligatedto defend because it was aware of “truefacts” that established coverage. According
to the policyholder, “true facts” establishingcoverage were set forth in the policyholder’sanswer to the complaint and in affidavits
executed by the policyholder’s employees.
The Fifth Circuit rejected this argument,
stating that:
We do not interpret the “true facts”
rule to require an insurance company,
when the claim is outside coverage,
to consider the denials in an answer
when deciding whether to defend or toreview affidavits from the insured that
support the denials. Such a rule would
transform the narrow exception into a
broad one.

Fifth Circuit Affirms That
Misappropriation and Unfair
Competition Claims Do Not Allege
Personal and Advertising Injury
Our April 2014 Alert reported on a Mississippi
federal district court decision holding that ageneral liability insurer had no duty to defend
or indemnify misappropriation and unfair
6Florida Court Rules That Statutory
Violation Exclusion Bars Coverage
for Conversion ClaimA Florida federal district court ruled that aninsurer had no duty to defend a suit alleging
both statutory and common law conversion
claims because the policy’s Violation of
Statutes exclusion barred coverage for bothclaims. Am. Cas. Co. of Reading, Pa. v.
Superior Pharmacy, LLC, No. 8:13-cv-622(M.D. Fla. Jan. 8, 2015).
A class action was filed against the policyholder alleging violations of the Telephone
Consumer Protection Act (“TCPA”) andconversion, based on the transmission of
unsolicited fax advertisements. American
Casualty sought a declaration that it had no
duty to defend or indemnify the claims basedon the Violation of Statutes exclusion, whichbarred coverage for damage “arising directly
or indirectly out of any action or omissionthat violates or is alleged to violate” the TCPA.
Although the policyholder did not disputethat the exclusion barred coverage for the
TCPA claim, it argued that it did not apply
to the common law conversion claim. The
court disagreed.
The court concluded that the conversion claim“arose out of” an alleged violation of the TCPA
because it was based on the same operative
facts. The court noted that under Florida law,
the phrase “arising out of” is broader than
the term “caused by” and is comparable to“having a connection with.” The court foundit immaterial that the conversion claim arose
under common law and required different
elements of proof and sought independent
damages. Additionally, the court dismissed
the policyholder’s argument that the statutory
exclusion did not bar coverage for theconversion claim because some of the faxes
might constitute conversion yet not violate
the TCPA. In rejecting this contention, thecourt explained that possible factual defenses
to the TCPA claim were irrelevant to the duty
to defend analysis because regardless of themerits of the TCPA claim, the “conversion
claim arises out of conduct alleged to haveviolated the TCPA.”
Policyholders have frequently sought
coverage for TCPA-related claims undergeneral liability policies. The first wave of
TCPA coverage litigation focused on whether
such claims alleged a violation of the “rightto privacy” under personal and advertising

injury provisions. See March 2010 Alert;
October 2011 Alert; October 2012 Alert.
Subsequent coverage litigation addressed
whether TCPA-based damages constituteuninsurable punitive damages. See June and
September 2013 Alerts. With many generalliability insurance policies now including
statutory violation exclusions, more recent
decisions have addressed the applicationof such exclusions to TCPA or related
non-statutory claims. See April and May
2014 Alerts.

Discovery Alert:

Courts Reach Conflicting
Conclusions as to Whether an
Insurer Waived Privilege by Putting
Advice of Counsel At Issue
In two recent decisions, the Arizona Courtof Appeals and the Tenth Circuit reacheddifferent conclusions as to whether an insurer
waived attorney-client privilege by putting theadvice of counsel at issue.
In Everest Indem. Ins. Co. v. Rea, 2015
WL 195450 (Ariz. Ct. App. Jan. 15, 2015),
the Arizona Court of Appeals accepted“special action jurisdiction” to address
whether an insurance company impliedly
waived attorney-client privilege by asserting
subjective good faith as a defense in a bad
faith action. The court held that it did not.
A policyholder alleged that Everest settled
an underlying suit in bad faith. Everest
countered that the decision to settle wasmade in good faith “based on its subjective
beliefs concerning the relative merits of thevarious courses of action.” Although Everest
acknowledged that it communicated withcounsel in making that decision, it did not
specifically assert that it relied on the adviceof its attorneys in opting to settle. The court
held that such conduct was insufficient toestablish “at issue” waiver of privilege.
Under Arizona law, in order to waive privilege
by putting the advice of counsel at issue,“a party must do more than simply confer
with counsel and take action incorporating
counsel’s advice.” Rather, waiver may
be implied only “when, after receiving
advice from an attorney, a party makes anaffirmative assertion that it was acting in goodfaith because it relied on counsel’s advice toinform its own evaluation and interpretation7

of the law.” In other words, implicit waiver
requires the assertion of a claim or defensethat is “dependent on” the advice of counsel;
the mere fact of consultation with counsel (or,as was the case here, participation of counsel
in settlement negotiations) is not enough.
Applying this standard, the court concluded
that Everest did not impliedly waive privilege
by putting the advice of counsel at issue. In
so ruling, the court noted that Everest had
not expressly cited the advice of counsel insupport of its subjective good faith.
In contrast, the Tenth Circuit ruled that aninsurer waived attorney-client and workproduct privilege by putting the advice of its
counsel at issue in litigation with a broker.
Seneca Ins. Co. v. Western Claims, Inc., 2014
WL 724071 (10th Cir. Dec. 22, 2014).
A property owner sought coverage for hail
damage from Seneca Insurance. Seneca hired
Western Claims to investigate the claim, whoestimated the claim value at approximately$1,000. Seneca paid that amount and closed
its file. Several months later, the property
owner sought to reopen the file based on aroofing estimate of approximately $750,000.
When Seneca refused to pay, the ownerbrought suit alleging breach of contract andbad faith. During litigation, Seneca sought
advice from two attorneys. Based on thelegal advice received, Seneca settled with theproperty owner for $1 million. Seneca thensued Western Claims alleging negligence andseeking to recover the settlement payment.
During discovery, Seneca disclosed a claim

note that stated that Seneca had settled withthe property owner “on advice of Counsel.”Western Claims then sought to compel Seneca
to produce documents relied upon by Seneca
in settling the hail damage claim. Seneca
refused, claiming attorney-client privilege andwork-product protection. The district court
granted Western Claims’ motion to compel
and the Tenth Circuit affirmed.
The Tenth Circuit concluded that Seneca
had waived privilege by putting the adviceof counsel “at issue” in the litigation against
Western Claims. Although the Oklahoma
Supreme Court has not endorsed a specifictest for determining “at issue” waiver, theTenth Circuit held that such waiver requiresthat the party asserting privilege took “someaffirmative act” that put the protected
information at issue “by making it relevantto the case.” The Tenth Circuit further heldthat at issue waiver requires a showing thatenforcing privilege would deny the opposing
party access to information “vital to [its]defense.” The court found that these elements
were established here because Seneca took
the affirmative act of filing suit against
Western Claims and then relied on the adviceof counsel to justify the reasonableness ofthe settlement. The court also deemed thematerial “vital” to Western Claims because theadvice of counsel was the only basis asserted
for justification of the settlement. Seneca
Insurance serves as an important reminderthat “attorney-client communications cannot
be used both as a sword and a shield.”8Simpson Thacher has been an international leader in the practice of insurance and reinsurance law for
more than a quarter of a century. Our insurance litigation team practices worldwide.
Mary Kay Vyskocil+1-212-455-3093
mvyskocil@stblaw.com

Chet A. Kronenberg+1-310-407-7557
ckronenberg@stblaw.com

George S. Wang
+1-212-455-2228
gwang@stblaw.com

Andrew S. Amer
+1-212-455-2953
aamer@stblaw.com

Linda H. Martin+1-212-455-7722
lmartin@stblaw.com

Deborah L. Stein+1-310-407-7525
dstein@stblaw.com

David J. Woll
+1-212-455-3136
dwoll@stblaw.com

Bryce L. Friedman+1-212-455-2235
bfriedman@stblaw.com

Craig S. Waldman+1-212-455-2881
cwaldman@stblaw.com

Mary Beth Forshaw+1-212-455-2846
mforshaw@stblaw.com

Michael D. Kibler+1-310-407-7515
mkibler@stblaw.com

Elisa Alcabes+1-212-455-3133
ealcabes@stblaw.com

Andrew T. Frankel+1-212-455-3073
afrankel@stblaw.com

Michael J. Garvey+1-212-455-7358
mgarvey@stblaw.com

Lynn K. Neuner+1-212-455-2696
lneuner@stblaw.com

Tyler B. Robinson+44-(0)20-7275-6118
trobinson@stblaw.com

This edition of the
Insurance Law Alert was
prepared by Mary Beth Forshaw(mforshaw@stblaw.com/+1-212455-2846) and Bryce L. Friedman(bfriedman@stblaw.com/+1-212-4552235) with contributions
by Karen Cestari(kcestari@stblaw.com).

The contents of this publication are for informational purposes only. Neither this publication nor the
lawyers who authored it are rendering legal or other professional advice or opinions on specific facts
or matters, nor does the distribution of this publication to any person constitute the establishment of an
attorney-client relationship. Simpson Thacher & Bartlett LLP assumes no liability in connection withthe use of this publication. Please contact your relationship partner if we can be of assistance regardingthese important developments. The names and office locations of all of our partners, as well as ourrecent memoranda, can be obtained from our website, www.simpsonthacher.com.
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