Insurance Law Alert

December 2018

In This Issue
Damages For Insurer’s Breach Of Duty To Defend Not Capped At Policy
Limits, Says Nevada Supreme Court
The Nevada Supreme Court ruled that when an insurer breaches its duty to defend, damages
are not capped at policy limits; rather, an insurer may be liable for any consequential damages
caused by the breach. Century Surety Co. v. Andrew, 2018 WL 6609591 (Nev. Dec. 13, 2018).
(Click here for full article)“The teamdemonstrates
extremely high intellectand provides highly
practical advice.”– Chambers USA 2018(quoting a client)

Finding Exception To Finality Rule, Second Circuit Rules That Arbitrators
Retain Authority To Clarify Ambiguous Award
The Second Circuit recognized an exception to functus officio, ruling that when an arbitration
award is ambiguous, the arbitrators retain authority to clarify that award. General Re Life
Corp. v. Lincoln National Life Ins. Co., 2018 WL 6186078 (2d Cir. Nov. 28, 2018). (Click here
for full article)

Florida Court Rules That Panel’s Liability Award Was Not Final Because
Of Bifurcation Of Liability And Damages
A Florida federal district court ruled that a panel’s arbitration award as to liability was not
final, even though the parties agreed to bifurcate arbitration between liability and damages.
Lowell at Camelot, Inc. v. New Home Warranty Ins. Co., No. 18-cv-21155 (S.D. Fla. Nov. 28,2018). (Click here for full article)

California Court Refuses To Compel Consolidated Arbitration, RulingThat Consolidation Is Issue For Panel To Decide
A California federal district court granted a reinsurer’s motion to compel appointment of anarbitrator and denied an insurer’s cross-motion to compel consolidated arbitration, rulingthat the question of whether multiple disputes should be consolidated should be decided by anarbitration panel. Employers Ins. Co. of Wausau v. The Hartford, 2018 WL 6330425 (C.D. Cal.
Dec. 3, 2018). (Click here for full article)

Second Circuit Dismisses Policyholder’s Breach Of Contract Claims
Against Insurer Based On Insurer’s Settlement
The Second Circuit affirmed a decision dismissing breach of contract and bad faith claims
against an insurer, finding that the insurer’s decision to settle claims asserted against it did not
violate any contractual duties that the insurer owed to its policyholder. Keller Foundations,
LLC v. Zurich American Ins. Co., 2018 WL 6431537 (2d Cir. Dec. 6, 2018). (Click here forfull article)
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Simpson Thacher & Bartlett LLP

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Two Connecticut Courts Find No Coverage For Cracking Concrete Claims
In recent weeks, two Connecticut federal district courts held that a property insurer has no
obligation to pay for losses related to the cracking and deterioration of concrete foundations
because such damage did not constitute a covered “collapse.” Cockill v. Nationwide Property &Cas. Ins. Co., 2018 WL 6182422 (D. Conn. Nov. 27, 2018); Hyde v. Allstate Ins. Co., 2018 WL
6331799 (D. Conn. Dec. 4, 2018). (Click here for full article)

California Court Rules That Primary Insurer’s Settlement Does Not Bind
Excess Insurer To Cover Uninsurable Loss
A California federal district court ruled that a second-tier excess carrier was not obligatedto cover uninsurable disgorgement payments notwithstanding that a primary and first layer
carrier had settled those claims up to their policy limits. AXIS Reinsurance Co. v. Northrop
Grumman Corp., No. 2:17-CV-8660 (C.D. Cal. Nov. 21, 2018). (Click here for full article)

Eighth Circuit Affirms Certification Of Class Action Against State Farm
Based On Labor Depreciation
The Eighth Circuit affirmed an Arkansas district court decision certifying a class of
homeowners who allege that State Farm improperly withheld amounts for labor depreciation
when making claim payments. Stuart v. State Farm Fire & Casualty Co., 2018 WL 6358447(8th Cir. Dec. 6, 2018). (Click here for full article)

Simpson Thacher News Alert
Click here for news relating to Simpson Thacher’s insurance-related honors.

2Damages Alert:

Damages For Insurer’s Breach
Of Duty To Defend Not Capped
At Policy Limits, Says Nevada
Supreme Court
The Nevada Supreme Court ruled that when
an insurer breaches its duty to defend,
damages are not capped at policy limits;rather, an insurer may be liable for any
consequential damages caused by the breach.
Century Surety Co. v. Andrew, 2018 WL
6609591 (Nev. Dec. 13, 2018).
The coverage dispute arose out of an
automobile accident involving a truck thatwas used by the driver for both personal andbusiness use. Century provided commercial
liability insurance to Blue Streak, the driver’s
employer. Century refused to defend Blue
Streak in the underlying personal injury
litigation on the basis that the driver was not
acting within the scope of his employment
at the time of the accident. After the parties
to the underlying litigation settled, theinjured party, as assignee of Blue Streak,sued Century, alleging breach of contract andbad faith.
A Nevada federal district court ruled that
Century breached its contractual duty to
defend but did not act in bad faith. As tothe scope of permissible damages, the court
certified the following question to the Nevada
Supreme Court:[w]hether, under Nevada law, theliability of an insurer that has breached
its duty to defend, but has not acted inbad faith, is capped at the policy limit
plus any costs incurred by the insured
in mounting a defense, or [whether]
the insurer [is] liable for all losses
consequential to the insurer’s breach.
The Nevada Supreme Court noted that the
majority of courts have concluded that where
there is no bad faith, damages are ordinarily
limited to the amount of policy coverage,plus attorneys’ fees and costs. However, thecourt adopted the minority view, holding thatdamages arising from a breach of the duty to
defend are not automatically capped at policy
limits plus defense costs. The court reasoned
that the “objective is to have the insurer ‘paydamages necessary to put the insured in thesame position he would have been in had theinsurance company fulfilled the insurance
contract.’” Thus, a party aggrieved by aninsurer’s refusal to defend may be entitled torecover all consequential damages flowing
from that breach, including any underlying
judgment, plus interest.
Importantly, the court noted that apolicyholder is not automatically entitled torecover the entire underlying judgment as aconsequence of the insurer’s breach. Rather,
the policyholder must establish that aninsurer’s breach of the duty to defend caused
an excess judgment.

Arbitration
Alerts:Last month’s Alert discussed a New Yorkappellate court decision that vacated a“corrected” arbitration award because thepanel exceeded its authority by reconsideringa final award it had previously rendered.
In that decision, the court held that:(1) the corrected award violated the principleof functus officio, which prevents a panel
from reconsidering a final award; and (2)the panel’s belief that its original award was
not final because the arbitration was notbifurcated was erroneous. In recent weeks,
two additional decisions have addressed
these issues.

Finding Exception To Finality
Rule, Second Circuit Rules That
Arbitrators Retain Authority To
Clarify Ambiguous Award
The Second Circuit recognized an exception tofunctus officio, ruling that when an arbitration
award is ambiguous, the arbitrators retain
authority to clarify that award. General Re

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Life Corp. v. Lincoln National Life Ins. Co.,2018 WL 6186078 (2d Cir. Nov. 28, 2018).
The reinsurance dispute between General
Re and Lincoln centered on whether General
Re was entitled to increase the premiums oncertain life insurance policies. An arbitration
panel issued an award holding that theagreement between the parties allowed
General Re to increase the premiums andalso allowed Lincoln to recapture the policies
rather than pay the increased premiums. The
award stated that “[a]ll premium and claim
transactions paid by one party to the otherfollowing the effective date of the recapture(i.e., from April 1, 2014) shall be unwound.”The parties took different positions as to how
this language applied to premium payments
made prior to April 1, 2014.

Lincoln petitioned the panel for guidance on
the issue. General Re objected to the request,
arguing that the panel would exceed its
authority if it reconsidered or fundamentallychanged the final award. Thereafter, the panel
issued a “Clarification,” stating that the final
award was ambiguous and that both parties
were reading it in a manner inconsistent
with the parties’ reinsurance agreement. The
Clarification explained that General Re wasentitled to retain all premiums paid prior to
April 1, 2014, including unearned premiums,
but that it remained liable for paying claims
for all covered deaths, even those that
occurred after April 1, 2014. A Connecticut
federal district court granted Lincoln’s
petition to confirm the Clarification anddenied General Re’s petition to confirm theoriginal award. The Second Circuit affirmed.
Under the doctrine of functus officio, once
an arbitration panel has fully exercised
its authority to adjudicate the issues
submitted to it, its authority ceases andthe panel has no further authority toreconsider those issues. However, theSecond Circuit recognized an exception tofunctus officio where, as here, an award issusceptible to more than one interpretation
or fails to address a contingency that later
arises. The court emphasized the limited
nature of the exception, stating thatthree conditions must be met to justify aclarification: (1) the final award is ambiguous;(2) the clarification clarifies the award
rather than substantively modifies it;and (3) the clarification is consistent withthe parties’ underlying agreement.

Florida Court Rules That Panel’s
Liability Award Was Not Final
Because Of Bifurcation Of Liability
And Damages
A Florida federal district court ruled that apanel’s arbitration award as to liability was
not final, even though the parties agreed tobifurcate arbitration between liability anddamages. Lowell at Camelot, Inc. v. New
Home Warranty Ins. Co., No. 18-cv-21155(S.D. Fla. Nov. 28, 2018).
New Home Warranty provided structuraldefect warranty coverage for a home built
by Lowell. When the home began to fallapart, the parties disputed whether New
Home Warranty was obligated to cover
the loss. The contract contained a clausethat required arbitration by Construction
Dispute Resolution Services (“CDRS”). CDRS
procedures bifurcate arbitration into twophases: a first phase addressing whether
damage is covered and a second phaseestablishing how damages are to be allocated.
After phase 1 is complete, the parties caneither settle the damages issue on their own
or return to arbitration for phase 2.
With respect to the structural defect warranty
claim, the panel issued an award in favor ofLowell at the conclusion of phase 1. Lowell
petitioned the court to confirm the award,
and New Home Warranty moved to dismiss
based on lack of subject matter jurisdiction,
arguing that it was interim, not final. The
court agreed and dismissed the suit. The court
acknowledged that “the text of the arbitration
award may suggest finality,” but reasoned
that the award was not final because theunresolved damages issue was related directly
to the phase 1 “merits questions.” The court
further explained that because the arbitrationagreement encompassed both liability anddamages, it was reasonable to infer that the4parties meant to resolve both issues in asingle proceeding. Finally, as to the bifurcatednature of the arbitration, rather than finding
it indicative of finality, the court stated “thatthe parties arbitrated under a bifurcatedproceeding in and of itself demonstrates
the lack of finality in this process because it
assumes a second arbitration.”

California Court Refuses To Compel
Consolidated Arbitration, RulingThat Consolidation Is Issue For
Panel To Decide
A California federal district court granted areinsurer’s motion to compel appointment ofan arbitrator and denied an insurer’s crossmotion to compel consolidated arbitration,
ruling that the question of whether multiple
disputes should be consolidated should be
decided by an arbitration panel. Employers
Ins. Co. of Wausau v. The Hartford, 2018 WL
6330425 (C.D. Cal. Dec. 3, 2018).
Hartford billed Wausau under nineteen
reinsurance treaties that Hartford and severalof its affiliates had purchased from Wausau.
When Wausau refused to pay, Hartford andits affiliates collectively demanded arbitration.
In its demand, Hartford requested that
Wausau name one arbitrator to serve on asingle panel for a consolidated arbitration.
In response, Wausau argued that threearbitrations needed to take place (one foreach Hartford entity) and appointed threeparty arbitrators. Wausau argued that a single
consolidated arbitration was not warranted
because Hartford’s demand involved multiple
contracts, each with its own arbitration
provision. Wausau moved to compel
arbitration of one particular contract (“Treaty2718”), seeking an order directing Hartford toproceed with the umpire selection process set
forth in the arbitration clause of that contract.
Hartford cross-moved for an order directing
Wausau to select one arbitrator to participate
in a single consolidated arbitration.
The court granted Wausau’s motion tocompel, noting that it was bound to enforce
the operative arbitration agreement inTreaty 2718, which does not contemplate
consolidation. The court directed the twoparty-appointed arbitrators to select anumpire pursuant to the procedures set forthin the arbitration provision in Treaty 2718.
The court further held that once a panel wasin place, it would have authority to decide theissue of consolidation, noting that a majority
of courts have ruled that such questions arearbitration panel decisions.
In denying Hartford’s cross-petition forconsolidation, the court rejected Hartford’s
assertion that all of the companies
collectively demanding arbitration wereacting as a single party for the purpose of
seeking reimbursement from Wausau forthe same underlying settlement payment.
The court explained that each Hartford
affiliate was a distinct entity and that thearbitration provisions in various treaties
differed as to umpire selection process andvenue. The court stated: “the Court cannot
compel Wausau to form a single arbitration
panel based on the fact that the parties
demanding arbitration are all Hartford
affiliates. . . . Harford’s cross-motion tocompel is a de facto request for the Court tofashion a new procedure in contravention of
the terms of the agreements.”

Breach Of
Contract Alert:

Second Circuit Dismisses
Policyholder’s Breach Of Contract
Claims Against Insurer Based On
Insurer’s Settlement
The Second Circuit affirmed a decisiondismissing breach of contract and bad
faith claims against an insurer, findingthat the insurer’s decision to settle claims
asserted against it did not violate any
contractual duties that the insurer owed toits policyholder. Keller Foundations, LLC v.
Zurich American Ins. Co., 2018 WL 6431537(2d Cir. Dec. 6, 2018).
Zurich insured Keller Foundations undera general liability policy. Diaz, a general5contractor, sued Zurich, arguing that it wasan additional insured under the policy. The
parties settled that suit with a payment of$450,000 from Zurich to Diaz. Thereafter,
Zurich obtained reimbursement for thesettlement from Capital Insurance pursuant
to a reinsurance agreement. After Capital paid
Zurich, Capital then sought reimbursementfrom Keller because Capital is owned and fully
funded by Keller.
After Keller reimbursed Capital, Keller sued
Zurich alleging breach of contract and the
duty of good faith and fair dealing. Keller
argued that Zurich breached its duties under
the liability policy by settling the suit with
Diaz and then seeking reimbursement from
Capital. Keller argued that Zurich had a duty
not to “use Policy funds to defend and settle aclaim that sought to impose liability on Zurich
itself.” A New York district court rejected thisargument and granted Zurich’s motion todismiss. The Second Circuit affirmed.
The Second Circuit held that Keller failed
to allege breach of contract because theinsurance policy did not bar Zurich fromsettling claims against it, and even assuming
it did, Keller failed to allege any damages
flowing from that settlement. The court
rejected Keller’s assertion that it was damaged
because it was obligated to reimburse Capitalfor a portion of the settlement and to pay a
deductible under the reinsurance agreement.

foundations because such damage did notconstitute a covered “collapse.”
In Cockill v. Nationwide Property & Cas.
Ins. Co., 2018 WL 6182422 (D. Conn. Nov.
27, 2018), homeowners sought coveragefor cracking in the concrete foundation of
their home. An inspector concluded that theconcrete was undergoing a chemical reaction
and would have to be replaced. Nationwide
denied coverage. The court agreed with
the insurer that the claims did not allege a“collapse,” defined as the “abrupt falling down
or caving in” of a structure “with the resultthat it cannot be occupied for its intended
purpose.” The court emphasized policy
language stating that a structure is not in astate of collapse if it is still standing, even if it
is “in danger of falling down or caving in” or“shows signs of . . . cracking.” Based on thisunambiguous language, the court concluded
that the homeowners’ allegations of
substantial impairment of structural integrity
did not trigger coverage under the collapse
provision. In so ruling, the court noted thateven if the concrete walls were deterioratingand essentially caving in, the damage would
be gradual, not “abrupt” as required by
the policy.

Construction
Defect Alert:

Two Connecticut Courts Find No
Coverage For Cracking Concrete
ClaimsOur October 2018 Alert discussed a Second
Circuit decision holding that a property
insurer had no duty to cover losses arisingfrom the cracking and deterioration of
concrete walls in the policyholders’ residence.
See Kim v. State Farm Fire & Cas. Ins. Co.,2018 WL 4847195 (2d Cir. Oct. 5, 2018).
Dozens of other cases involving this issue
are currently pending in Connecticut courts.
In recent weeks, two Connecticut federal
district courts held that a property insurer
has no obligation to pay for losses related tothe cracking and deterioration of concrete

Additionally, the court rejected thehomeowners’ assertion that losses due toa chemical reaction are not excluded fromcoverage. Although “chemical reactions” wasnot specifically listed among the enumerated
exclusions, the court found that other listed
exclusions (e.g., wear and tear, deteriorationand inherent vice), were broad enoughto encompass chemical reactions. In any
event, the court held that the only observed
manifestation of the chemical reaction was
the foundation cracking, which was excluded
under the collapse provision.
Finally, the court dismissed the homeowners’
claim for reimbursement of “reasonable
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costs you incur for necessary repairs madesolely to protect covered property fromfurther damage,” noting that this provisionapplies only “if the peril causing the loss
is covered.” Here, because the cracking
concrete fell outside the scope of coverage,
the court deemed the reasonable repairs
provision inapplicable.
In Hyde v. Allstate Ins. Co., 2018 WL
6331799 (D. Conn. Dec. 4, 2018), the court
reached the same conclusion, ruling that
concrete cracking, decay and oxidization inbasement walls was not a covered loss undera homeowners’ policy. The court held thatthe gradual deterioration of the concrete
walls was not “sudden and accidental direct
physical loss,” as required by the policy.
Further, the court found no coverage under acollapse provision, which similarly required
the collapse to be “sudden.” The court
explained that “sudden” is unambiguous
and requires “temporal abruptness.” Thehomeowners’ claims failed to allege thisrequirement because they asserted that the
decay process occurred “over the course ofyears” – notwithstanding allegations that the
decay would ultimately result in “complete
degradation” and/or “sudden events
throughout the course of decay,” such as
shifting, bulging or cracking.

In other defective concrete news, thismonth the Connecticut Supreme Courtis scheduled to hear arguments in Karasv. Liberty Ins. Corp., 2018 WL 2002480(D. Conn. Apr. 30, 2018) (discussed in
our May 2018 Alert). There, the court willaddress the following certified question:“what constitutes ‘substantial impairment ofstructural integrity’ for purposes of applying
the ‘collapse’ provision of this homeowners’
insurance policy?” We will keep you posted onany developments in this matter.

Excess Alert:

California Court Rules That
Primary Insurer’s Settlement Does
Not Bind Excess Insurer To CoverUninsurable Loss
A California federal district court ruled that asecond-tier excess carrier was not obligatedto cover uninsurable disgorgement payments
notwithstanding that a primary and firstlayer carrier had settled those claims up to
their policy limits. AXIS Reinsurance Co.
v. Northrop Grumman Corp., No. 2:17-CV8660 (C.D. Cal. Nov. 21, 2018).
Northrop was insured under a primary policy
issued by National Union, a first layer excess
policy issued by Continental Casualty and asecond layer policy issued by AXIS. Northropsought coverage from the insurers for asettlement with the Department of Labor
relating to certain alleged wrongful activity.
National Union and Continental Casualty paid
amounts equal to the remaining limits of theirpolicies. AXIS made some payment, but filed
suit seeking reimbursement on the basis thatits policy was “unnecessarily triggered as aresult of improper erosion.”
The court granted AXIS’s summary judgment
motion, finding that the underlying
settlement was an uninsurable loss. The
court reasoned that the settlement consistedof uninsurable disgorgement payments
because the Department of Labor specifically
instructed Northrop to restore all payments orreimbursements made in violation of ERISA.
Although “disgorgement” was not used in thesettlement, the court concluded that it was
clear from the investigation and settlementthat Northrop was returning ill-gotten gains.
Further, the court ruled that AXIS was not
obligated to provide coverage as a result of
the lower level insurers’ decision to pay forthe settlement and the exhaustion of theirpolicies. The court explained that AXIS was
not bound by the independent decisions of theunderlying insurers when its own policy did
not provide coverage. The court distinguishedcases in which courts have prohibited excess
insurers from challenging a primary carrier’s
payment decisions on the basis that thosecases involved losses that were within thescope of coverage under the excess policy.

7Class Action Alert:with common evidence. Distinguishing cases
in which commonality was not found becauseof case-by-case differences in calculatingclaim values, the court emphasized that
here, the policies specified the method for
calculating actual cash value payments.

The Eighth Circuit affirmed an Arkansas
district court decision certifying a class of
homeowners who allege that State Farm
improperly withheld amounts for labor
depreciation when making claim payments.
Stuart v. State Farm Fire & Casualty Co.,2018 WL 6358447 (8th Cir. Dec. 6, 2018).

The Eighth Circuit also rejected State Farm’s
contention that class certification was
inappropriate because certain plaintiffs lacked
standing. State Farm argued that plaintiffs
who completed repairs at or below the costof the ACV payment did not suffer injury andthus lacked standing. The court disagreed,finding that any individual that received
an improperly-depreciated ACV payment
suffered a legal injury “regardless of whether
the ACV payment was more than, less than,or exactly the same as the ultimate cost of
repairing or replacing their property.”

Eighth Circuit Affirms Certification
Of Class Action Against State Farm
Based On Labor Depreciation

The class consists of State Farm policyholders
who allege that State Farm improperly
depreciated the costs of labor whencalculating “actual cash value” (“ACV”)
payments under their policies. The
district court concluded that the plaintiffs
demonstrated that “questions of law or factcommon to class members predominate
over any questions affecting any individual
members,” as required by Federal Rule ofCivil Procedure 23(b)(3). Affirming the ruling,
the Eighth Circuit found that plaintiffs’ claims
shared a common, predominating question oflaw – namely, whether State Farm breached
its contracts by depreciating labor costs
when calculating claim payments. The Eighth
Circuit rejected State Farm’s assertion that
individual issues of liability and damages exist
for each plaintiff that cannot be established

Simpson Thacher
News Alert
Euromoney’s Benchmark Litigation 2019recognized Simpson Thacher’s Insurance
Litigation Department as Tier 1. The Firm
has received consecutive National Top-Tierrankings in the category of Insurance since
2008.

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

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

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

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

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

Susannah S. Geltman+1-212-455-2762
sgeltman@stblaw.com

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

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

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ealcabes@stblaw.com

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

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

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

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

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

Daniel J. Stujenske+1-212-455-2419
dstujenske@stblaw.com

Simpson Thacher sends warm season’s greetings and best wishes for a wonderful new year.

This edition of the
Insurance Law Alert was
prepared by Mary Beth Forshaw
mforshaw@stblaw.com /+1-212-4552846 and Bryce L. Friedman
bfriedman@stblaw.com /+1-212-4552235 with contributions
by Karen 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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Please click here to subscribe to the Insurance Law Alert.
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