Insurance Law Alert

September 2023

In This Issue
Hawaii District Court Certifies Climate Change Coverage Question
To Hawaii Supreme Court
A Hawaii district court asked the Hawaii Supreme Court to decide whether recklessconduct can be a covered “occurrence” under an insurance policy and whether
greenhouse gases are pollutants within the meaning of a pollution exclusion. Aloha
Petroleum, Ltd. v. National Union Fire Ins. Co. of Pittsburgh, PA, 2023 U.S. Dist.
LEXIS 156211 (D. Haw. Sept. 5, 2023). (Click here for full article)“If you have amajor issue, an
exceptionally high value
or critical claim, Simpson
is where you turn.”– The Legal 500(quoting a client)

Noting Possible Distinction Between Acquisition And Merger
Transactions, Delaware Court Deems Bump-Up Exclusion
Ambiguous
A Delaware trial court granted a policyholder’s motion for partial summary judgment,
ruling that a bump-up exclusion was ambiguous and must be construed narrowly infavor of coverage. Viacom Inc. v. U.S. Specialty Ins. Co., 2023 Del. Super. LEXIS 728(Del. Super. Ct. Aug. 10, 2023). (Click here for full article)

Illinois Court Dismisses Some, But Not All, Causes Of Action
Against Insurer Alleging Racial Discrimination In Claims Handling
Practices Based On Artificial Intelligence Algorithms
An Illinois district court granted in part and denied in part an insurer’s motion
to dismiss a putative class action law suit alleging racial discrimination in claims
handling practices based on the insurer’s use of algorithmic decision-making tools.
Huskey v. State Farm Fire & Cas. Co., 2023 U.S. Dist. LEXIS 160629 (N.D. Ill. Sept.
11, 2023). (Click here for full article)

North Carolina Court Finds That Nuisance Claims Arise From A
Single Accident And Are Subject To Pro Rata Allocation AcrossMultiple Policy Periods
In a pair of decisions, a North Carolina trial court ruled that underlying nuisanceclaims stemming from hog farm operations arose out of a single accident for insurance
coverage purposes and that pro rata allocation was the appropriate method for
determining each insurer’s liability. Murphy-Brown, LLC v. ACE American Ins. Co.,
2023 NCBC LEXIS 93 (N.C. Super. Ct. Aug. 7, 2023); Murphy-Brown, LLC v. ACE
American Ins. Co., 2023 NCBC LEXIS 94 (N.C. Super. Ct. Aug. 7, 2023). (Click here
for full article)
Simpson Thacher & Bartlett LLP

1

Policy Exclusions Do Not Bar Coverage For Opioid-Related Claims
Against Pharmaceutical Distributor, Says North Carolina Court
A North Carolina district court granted a policyholder’s summary judgment motion,
ruling that contract and professional service exclusions in a claims-made policy
did not bar coverage for underlying opioid-related claims. North Carolina Mutual
Wholesale Drug Co. v. Federal Ins. Co., 2023 U.S. Dist. LEXIS 147248 (M.D.N.C. Aug.
17, 2023). (Click here for full article)

Ninth Circuit Seeks Guidance From Alaska Supreme Court About
Applicability Of Pollution Exclusion To Carbon Monoxide Claims
The Ninth Circuit asked the Alaska Supreme Court to decide whether a pollution
exclusion bars coverage for claims arising out of carbon monoxide poisoning, a matterof first impression under Alaska law. Estate of Wheeler v. Garrison Prop. & Cas. Ins.
Co., 2023 U.S. App. LEXIS 23648 (9th Cir. Sept. 6, 2023). (Click here for full article)2

Hawaii District Court Certifies Climate Change Coverage
Question To Hawaii Supreme Court
HOLDINGA Hawaii district court asked the Hawaii Supreme Court to decide whether recklessconduct can be a covered “occurrence” under an insurance policy and whether greenhousegases are pollutants within the meaning of a pollution exclusion. Aloha Petroleum, Ltd. v.
National Union Fire Ins. Co. of Pittsburgh, PA, 2023 U.S. Dist. LEXIS 156211 (D. Haw.
Sept. 5, 2023).

BACKGROUND

Two lawsuits against Aloha Petroleum and twenty other fossil fuel entities alleged that thedefendants knew that their products created greenhouse gas pollution that resulted inharmful climate change and tangible harm to the plaintiff communities, but nonethelesscontinued to promote fossil fuel use. In this coverage action, Aloha Petroleum seeks adeclaration that AIG has a duty to defend the underlying suits.

DECISION

The court explained that AIG’s defense obligations turned on resolution of two issues:(1) whether the reckless conduct alleged in the complaint could constitute an “occurrence”
under the operative policies; and (2) whether greenhouse gases are “pollutants” (defined as“gaseous” “irritant[s] or contaminant[s], including smoke, vapor soot, fumes acids, alkalis,chemicals and waste”) for purposes of applying a pollution exclusion.
With respect to the first issue, Aloha Petroleum argued that an insured may engage in
conduct that is reckless, while still lacking intent or expectation of injury, such that acovered “occurrence” (defined in part as an “accident”) may be found. In contrast, AIG
asserted that recklessness cannot be an “accident” because recklessness generally requires
a risk of foreseeable harm that is disregarded by the tortfeasor.
As to application of the pollution exclusion, the court framed the central questions as
whether the pollution exclusion applies only to “traditional environmental pollution”
under Hawaii law, and if so, whether the production of greenhouse gases constitutes such“traditional environmental pollution.”

COMMENTS

Because this dispute relates to AIG’s duty to defend, the court’s
analysis will turn on a comparison of the allegations in theunderlying complaint with the policy language. Here, theunderlying suits expressly allege that the defendants had
knowledge about the resulting harm of their products but
continued to wrongfully market them. Such allegations arguably
contravene any categorization of Aloha Petroleum’s conduct as“accidental.”
With respect to the pollution exclusion, even under a very
narrow reading of the provision, it would seem incongruous tofind that the release of harmful gases into the atmosphere does
not fall within the scope of the plain language of the exclusion,
particularly in light of a 2007 Supreme Court decision findingthat greenhouse gases are “pollutants” under a provision of the
Clean Air Act.
We will keep you posted on the Hawaii Supreme Court’s rulingin this matter.

3

Noting Possible Distinction Between Acquisition And
Merger Transactions, Delaware Court Deems Bump-Up
Exclusion Ambiguous
HOLDINGA Delaware trial court granted a policyholder’s motion for partial summary judgment,
ruling that a bump-up exclusion was ambiguous and must be construed narrowly in favorof coverage. Viacom Inc. v. U.S. Specialty Ins. Co., 2023 Del. Super. LEXIS 728 (Del.
Super. Ct. Aug. 10, 2023).

BACKGROUND

In 2019, Viacom merged with CBS Corp. Pursuant to the merger agreement, Viacom ceased
to exist as a corporation and all “assets, rights, privileges, powers and franchises” of Viacom
vested in the surviving corporation, CBS. Additionally, all Viacom shares were converted
into CBS common stock. Following this transaction, Viacom stockholders brought several
lawsuits alleging breach of fiduciary duty against Viacom executives. In 2023, the suits
were settled for approximately $122 million.
Viacom’s D&O insurers denied coverage for the settlement, arguing that coverage wasbarred by a bump-up provision which stated that covered loss did not include: “[A]ny
amount representing the amount by which the price of or consideration paid or proposed
to be paid for the acquisition or completion of the acquisition of all or substantially all of
the ownership interest in, or assets of, an entity, including a Company, was inadequate oreffectively increased.”
The court concluded that the exclusion was ambiguous with respect to the undefined term
“acquisition” and therefore deemed it inapplicable.

DECISION

The court’s ruling as to ambiguity turned primarily on its finding that merger andacquisition could be two distinct business transactions. The court noted that the languagein other policy provisions relating specifically to mergers tracked the “acquisition” language
contained in the bump-up exclusion, but also contained explicit reference to “or the merger
or consolidation of the Company into or with another entity.” The court reasoned that theabsence of such references to merger in the bump-up exclusion raised doubt as to whether
it was intended to apply only to acquisition transactions.
The court acknowledged that one reasonable interpretation of the exclusion was that it
applied to the Viacom-CBS merger because that transaction resulted in CBS’s acquisitionof all Viacom’s assets, rights, privileges and franchises, as well as an ownership interest
in Viacom’s subsidiaries. However, the court held that an equally plausible reading of the
exclusion was that it applied exclusively to acquisitions, and not to merger transactions,such as the one at issue here. Having deemed the provision ambiguous, the court construed
it in favor of coverage.

COMMENTS

As reported in our May 2023 Alert, the Fourth Circuit reached a contrary conclusion in
Towers Watson & Co. v. National Union Fire Ins. Co. of Pittsburgh, PA, 67 F.4th 648 (4thCir. 2023). There, the Fourth Circuit reasoned that the “ordinary and accepted meaning” of“acquisition” contemplates the gaining of possession or control over something andtherefore encompassed the transaction at issue—a reverse triangular merger. The Fourth
Circuit stated that “nothing in the bump-up exclusion stipulates, or even hints, that theterm ‘acquisition’ was intended to refer only to a particular form of acquisition.” The
Viacom court distinguished Towers Watson based on its application of Virginia, rather
than Delaware, law.
4

Illinois Court Dismisses Some, But Not All, Causes Of
Action Against Insurer Alleging Racial Discrimination
In Claims Handling Practices Based On Artificial
Intelligence Algorithms
HOLDINGAn Illinois district court granted in part and denied in part an insurer’s motion to dismiss aputative class action law suit alleging racial discrimination in claims handling practices
based on the insurer’s use of algorithmic decision-making tools. Huskey v. State Farm Fire
& Cas. Co., 2023 U.S. Dist. LEXIS 160629 (N.D. Ill. Sept. 11, 2023).

BACKGROUND

Black homeowners alleged that State Farm’s use of certain algorithmic tools in its claims
handling process resulted in discriminatory treatment. More specifically, Blackhomeowners alleged that State Farm took longer to process their claims, required
additional paperwork and communication, and ultimately provided less coverage. The
complaint alleged that these racial disparities stem from State Farm’s use of “machinelearning algorithms,” which consider race as one of many factors in predicting fraud anddetermining whether claims should be paid. The plaintiff homeowners alleged disparate
impact race discrimination in violation of the Fair Housing Act (“FHA”), and also sought
injunctive and declaratory relief, damages and attorneys’ fees.

DECISION

The court dismissed two of the three FHA claims. Section 3604(a) of the FHA makes it
unlawful to refuse to sell or rent, or otherwise make unavailable, a dwelling to any person
because of race. The court ruled that plaintiffs’ claims were not within the scope of thisprovision because the complaint did not allege actual unavailability of the homes, butrather only a lack of habitability and diminution in property value due to damage not being
promptly covered by State Farm. Similarly, the court ruled that plaintiffs’ allegations did
not state a viable claim under Section 3605 of the FHA, which prohibits any “entity whosebusiness includes engaging in residential real estate-related transactions” fromdiscriminating based on race. Relying on a Seventh Circuit decision holding that insurers
are not “entities who engage in covered transactions under [Section] 3605,” the court
dismissed the claim.
However, the court declined to dismiss a claim under Section 3604(b), which prohibits
discrimination “in the terms, conditions, or privileges of sale or rental of a dwelling, orin the provision of services or facilities in connection therewith, because of race.” Thecourt explained that under the broad language of this provision, property insurance—inparticular, claims handling operations—could plausibly constitute a service in connection
with the sale of a home. Having reached that conclusion, the court addressed whether
plaintiffs adequately alleged disparate impact. The court ruled that they did, based on thefollowing three factors: (1) allegations of statistical disparities among a large cross sectionof insured homeowners, (2) State Farm’s utilization of algorithmic decision-making tools toautomate claim processing, and (3) a purported causal connection between the policy andstatistical racial disparities.
Additionally, the court declined to dismiss the suit based on the doctrine of reversepreemption. State Farm argued that the federal FHA claims were reversed-preemptedby Illinois state law under the McCarran-Ferguson Act, which holds that federal laws ofgeneral application may not displace state laws that specifically relate to the business of
insurance. State Farm argued that Illinois statutes relating to claims handling procedures
5conflict with the FHA and therefore reverse preempt the federal statute. Rejecting thisassertion, the court held that there was no conflict between state and federal law in thiscontext and that application of the FHA would not disrupt Illinois’s insurance-related
administrative regime.
COMMENTS

Claims based on an insurance company’s use of computers to assist human decisionmaking are not new. However, claims are likely to proliferate in the near term as theperceived consequences of the use of such tools become more obvious to consumers,
employees or other individuals. With respect to the FHA, Huskey emphasized that“disparate-impact liability must have limits” and should not be based solely on a showing ofstatistical disparity; instead, such claims require “careful examination” of the company
policies at issue and the existence (or lack thereof) of a causal connection between thepolicies and any statistical disparities.

North Carolina Court Finds That Nuisance Claims Arise
From A Single Accident And Are Subject To Pro Rata
Allocation Across Multiple Policy Periods
HOLDING

In a pair of decisions, a North Carolina trial court ruled that underlying nuisance claims
stemming from hog farm operations arose out of a single accident for insurance coveragepurposes and that pro rata allocation was the appropriate method for determining each
insurer’s liability. Murphy-Brown, LLC v. ACE American Ins. Co., 2023 NCBC LEXIS 93(N.C. Super. Ct. Aug. 7, 2023); Murphy-Brown, LLC v. ACE American Ins. Co., 2023
NCBC LEXIS 94 (N.C. Super. Ct. Aug. 7, 2023).

BACKGROUND

Property owners sued a hog farm operator, alleging physical invasion and loss of use andenjoyment of property due to odor, dust, noise, pests and traffic stemming from the hog
farm operations at multiple sites. According to the underlying complaint, the property
owners suffered repeated exposure to conditions over an extended period of time, during
which multiple insurance policies were in place. In two summary judgment motions, thecourt was asked to determine whether the claims in the underlying suits arose out of one
accident or multiple accidents under business automobile policies, and whether allocation
among various liability insurers should be based on pro rata time on the risk or an “allsums” method.

DECISION

The hog farm operator and a primary automobile insurer argued that there was only one“accident” under the operative policies because the alleged damages arose from the“centralized policies and procedures regarding the operation” of the farms, including theirtrucking operations. Conversely, excess insurers asserted that the underlying claims arosefrom 89 accidents, based on the operation of 89 separate farms and the accompanying
trucks serving those farms. The operative language provided coverage for injuries ordamage caused by an “accident” resulting from the ownership, maintenance or use of acovered automobile, and further stated that “[a]ll ‘bodily injury,’ ‘property damage,’ and‘covered pollution cost or expense’ resulting from continuous or repeated exposure to
substantially the same conditions will be considered as resulting from one ‘accident.’”
Applying a proximate cause-based test, the court concluded that the alleged injuries anddamages stemmed from a single accident. In so ruling, the court emphasized that the6injuries did not differ materially among the various farm sites and that conditions were
“essentially the same in all material respects.” More specifically, the court noted theexistence of a centralized trucking operation, as outlined in a standard manual utilized by
the hog farm operator.
With respect to allocation of indemnity costs, the court concluded that policy language
indicated that liability among multiple insurers that issued policies during the period of
alleged damage should be based on a pro rata time on the risk methodology. In particular,
the policies limited recovery to bodily injury or property damage (or in the case of auto
policies, accidents) that occurred “during the policy period.”
The hog farm operator argued that “all sums” allocation should apply, under which it may
recover the entirety of any loss from any single insurer that provided coverage during theongoing period of damages. The hog farm operator relied on a “Continuing Coverage”
provision included in certain policies, which stated that bodily injury or property damage
that occurs during the policy period “includes any continuation, change or resumption ofthat bodily injury or property damage after the policy period.” Rejecting this assertion,
the court reasoned that the Continuing Coverage provision did not establish an obligationon the part of the insurer to be liable for “all sums” arising from liability during any policy
period. Rather, the court held that the provision sets forth the “unremarkable” principlethat a policy in effect when the damage occurs will cover all consequential damages, eventhose occurring after the policy period.
COMMENTS

The court’s allocation ruling is notable in several respects. First, the court rejected thenotion that a policy’s inclusion of both “all sums” and “during the policy period” language
creates ambiguity that should be construed in the policyholder’s favor. Second, the courtemphasized the “modern trend” of courts across jurisdictions in applying pro rata
allocation, noting that “all sums” allocation represented an “outdated view” of relevant
policy language. Finally, the court’s refusal to construe the Continuing Coverage provision
as a mandate for “all sums” allocation is a significant ruling for insurers in this context, as it
draws a clear line between that type of policy clause and a non-cumulation clause, which
has been a basis for applying “all sums” allocation in other cases, such as In re Viking
Pump, 27 N.Y.3d 244 (2016), which the court expressly distinguished.

7

Policy Exclusions Do Not Bar Coverage For OpioidRelated Claims Against Pharmaceutical Distributor, Says
North Carolina Court
HOLDINGA North Carolina district court granted a policyholder’s summary judgment motion, rulingthat contract and professional service exclusions in a claims-made policy did not bar
coverage for underlying opioid-related claims. North Carolina Mutual Wholesale Drug Co.
v. Federal Ins. Co., 2023 U.S. Dist. LEXIS 147248 (M.D.N.C. Aug. 17, 2023).

BACKGROUND

Mutual Drug, a wholesale company that sold products to retail pharmacies, was sued innumerous lawsuits brought by municipalities, hospitals and individuals. The complaints
alleged that Mutual Drug failed to monitor or investigate suspicious orders by pharmacies
for prescription opioids, in violation of federal and state law and in breach of common law
duties among other things. Chubb refused to indemnify Mutual Drug for its defense costs
and liabilities on the basis of policy exclusions relating to contract and professional
services. The court ruled that neither provision applied to the underlying claims.

DECISION

The contract exclusion applied to any claim “based upon, arising from or in consequence ofany liability in connection with any oral or written contract or agreement.” Chubb argued
that this provision barred coverage because the underlying claims arose from liability inconnection with Mutual Drug’s wholesale distribution contracts with independent
pharmacies. Rejecting this contention, the court held that the underlying claims arose from
common law or regulatory duties, rather than those contracts. The court acknowledged thebreadth of the exclusion, but explained that “[t]he fact that the claims arise out of theinsured’s business and that the insured uses contracts in its business is not enough.”
Likewise, the court ruled that the professional services exclusion was inapplicable. While
the policy defined “professional services” as “services which are performed for others
for a fee,” the court concluded that none of Mutual Drug’s services could be categorized
as “professional” regardless of whether it charged fees to independent pharmacies. In
particular, the court explained that Mutual Drug’s commercial distribution of tangible
commodities does not constitute a professional service, “or indeed any service[ ] at all.” Thecourt rejected Chubb’s contention that by conducting compliance reviews in connection
with the sale of pharmaceutical products, it engaged in “services,” emphasizing thatthose reviews were undertaken in compliance withfederal, state, and local regulations for the sale ofpharmaceuticals and not in exchange for a separate fee
from customers.

COMMENTS

In the emerging area of opioid coverage litigation, mostdecisions have turned on whether the underlying claims
alleged a covered “occurrence” (as opposed to knowing
or intentional conduct) and/or covered “bodily injury”(as opposed to purely economic damages incurred bymunicipalities or other entities). The decision in thiscase addresses somewhat different issues of coverage inthis context and illustrates the limits some courts may
impose in construing certain policy exclusions.

8Ninth Circuit Seeks Guidance From Alaska Supreme
Court About Applicability Of Pollution Exclusion To
Carbon Monoxide Claims
HOLDING

The Ninth Circuit asked the Alaska Supreme Court to decide whether a pollution exclusion
bars coverage for claims arising out of carbon monoxide poisoning, a matter of first
impression under Alaska law. Estate of Wheeler v. Garrison Prop. & Cas. Ins. Co., 2023
U.S. App. LEXIS 23648 (9th Cir. Sept. 6, 2023).

BACKGROUND

The coverage dispute arose after a young man died from carbon monoxide poisoning whileliving in the home of the policyholders. When the decedent’s estate sued the homeowners,
the homeowners filed an insurance claim. The insurer denied coverage on the basis of apollution exclusion that applied to bodily injury or property damage “[a]rising out of theactual, alleged, or threatened discharge, dispersal, release, escape, seepage or migration of‘pollutants’ however caused and whenever occurring.” The policy defined pollutants as “anysolid, liquid, gaseous or thermal irritant or contaminant, including smoke, vapor, soot,fumes, acids, alkalis, chemicals and waste.”
The decedent’s estate, as assignees of the homeowners, sued the insurer, seeking adeclaration of coverage and an award of damages. An Alaska district court granted theinsurer’s summary judgment motion, finding that the suit fell within the scope of thepollution exclusion.

DECISION

The Ninth Circuit noted the history of extensive litigation and conflicting decisions acrossjurisdictions as to the scope of a pollution exclusion—both in general and in the context ofcarbon monoxide claims. Expressing uncertainty as to how the Alaska Supreme Court
would rule on this outcome-determinative issue, the Ninth Circuit certified the following
question: “Does a total pollution exclusion in a homeowners’ insurance policy exclude
coverage of claims arising from carbon monoxide exposure?”

COMMENTS

Courts that have declined to apply a pollution exclusion to carbon monoxide claims havegenerally reasoned that such exclusions are intended to apply only to “traditional
environmental pollution,” meaning claims of outdoor air, water or ground contamination
by industrial polluters, rather than discrete, isolated incidents of injury or damage causedby the release of an indoor pollutant. In contrast, a significant number of courts haveconcluded that the exclusion bars coverage for such claims, reasoning that carbon
monoxide is a pollutant and that the exclusion, by its plain terms, applies unambiguously.
Those decisions appear to be the better reasoned ones, as the language of the exclusion
itself lacks reference to any “traditional” or outdoor requirement and absent ambiguity,
consideration of legislative history or other extrinsic evidence is not warranted.

9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.

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

Laura Lin
+1-650-251-5160
laura.lin@stblaw.com

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

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

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

Summer Craig+1-212-455-3881
scraig@stblaw.com

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

Joshua Polster+1-212-455-2266
joshua.polster@stblaw.com

Sarah E. Phillips+1-212-455-2891
sarah.phillips@stblaw.com

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

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

Abigail W. Williams+1-202-636-5569
abigail.williams@stblaw.com

This edition of the
Insurance Law Alert was prepared byBryce L. Friedman / +1-212-455-2235
bfriedman@stblaw.com
Chet A. Kronenberg / +1-310-407-7557
ckronenberg@stblaw.com andKaren Cestarikcestari@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
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