Insurance Law Alert

March 2024

In This Issue
Fifth Circuit Rules That Insurance Dispute Is Subject To Arbitration
Under The Convention, Notwithstanding Dismissal Of Foreign Insurers
The Fifth Circuit granted domestic insurers’ motion to compel arbitration, finding that a
Louisiana statute barring arbitration of insurance disputes did not reverse preempt theConvention on the Recognition and Enforcement of Arbitral Awards. Bufkin Enterprises,
L.L.C. v. Indian Harbor Ins. Co., 2024 U.S. App. LEXIS 5176 (5th Cir. Mar. 4, 2024).
(Click here for full article)

Applying “Meaningfully Linked” Standard, Delaware Court Rules That
Securities Action Is Not “Related” To Previous SEC Action“[Simpson Thacher
is] able to handle
both direct insurance andreinsurance matters withequal flair, and also adept at
handling the most complex of
disputes regarding insurers’
business practices.”– Chambers USA 2023

A Delaware court ruled that a Securities and Exchange Commission subpoena and asubsequent securities action were not “meaningfully linked” for purposes of applying an
Interrelated Wrongful Acts provision and a Prior Notice Exclusion in a D&O policy. Alexion
Pharmaceuticals, Inc. v. Endurance Assurance Corp., 2024 Del. Super. LEXIS 103 (Del.
Super. Ct. Feb. 15, 2024). (Click here for full article)

Texas Supreme Court Rules That Policyholder Suffered A “Loss” By
Virtue Of Underlying Settlement, But That Settlement Is Not Binding In
Coverage Litigation
Granting conditional mandamus relief, the Texas Supreme Court ruled that a policyholder
suffered a covered “loss” because an underlying settlement rendered it “legally obligated topay,” but that the settlement was neither binding nor admissible in related coverage litigation.
In re Illinois National Ins. Co., 2024 Tex. LEXIS 158 (Tex. Feb. 23, 2024). (Click here forfull article)

Reversing District Court, First Circuit Rules That Insurer Is Not Entitled
To Recoup Defense Costs Or Settlement Payments From Insured
The First Circuit ruled that an insurer is not entitled to recover costs incurred in defending
its insured or in settling an excluded underlying claim. Berkley National Ins. Co. v. AtlanticNewport Realty LLC, 93 F.4th 543 (1st Cir. 2024). (Click here for full article)

Sixth Circuit Rules That District Court Erred In Dismissing Equitable
Contribution Claim By Insurer Against Fellow Insurers Based On
Untimely Notice
Reversing an Ohio district court decision, the Sixth Circuit ruled that an insurer’s equitable
contribution claim for reimbursement of pre-tender defense costs from non-defending insurers
should not have been dismissed based on untimely notice alone. ACE American Ins. Co. v.
Zurich Am. Ins. Co., 2024 U.S. App. LEXIS 5535 (6th Cir. Mar. 5, 2024).
(Click here for full article)
Simpson Thacher & Bartlett LLP

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Fifth Circuit Rules That Insurance Dispute Is Subject
To Arbitration Under The Convention, Notwithstanding
Dismissal Of Foreign Insurers
HOLDINGThe Fifth Circuit granted domestic insurers’ motion to compel arbitration, finding that a
Louisiana statute barring arbitration of insurance disputes did not reverse preempt theConvention on the Recognition and Enforcement of Arbitral Awards (the “Convention”).
Bufkin Enterprises, L.L.C. v. Indian Harbor Ins. Co., 2024 U.S. App. LEXIS 5176 (5th Cir.
Mar. 4, 2024).

BACKGROUND

Bufkin purchased surplus lines coverage from eight domestic insurers and two foreign
insurers. Each policy included an arbitration clause, as well as a provision stating that thepolicy “shall be constructed as a separate contract” between Bufkin and the insurer. The
parties disagreed as to whether the policies constituted a “single, all-encompassing
agreement” or discrete agreements between each insurer and Bufkin.
When a coverage dispute arose, Bufkin initially sued only the domestic insurers, but
subsequently filed an amended petition naming the foreign insurers as defendants for thesole purpose of dismissing them with prejudice and foregoing all rights against them. The
domestic insurers moved to compel arbitration pursuant to the Federal Arbitration Act(“FAA”) and the Convention.
The district court denied the motion, ruling that the Convention did not apply because
only the domestic insurers remained parties to the dispute. The district court also rejected
the insurers’ contention that the Convention could be invoked under an equitable estoppel
theory. Having determined that the arbitration provisions were governed only by the
FAA, the district court concluded that the FAA was reverse preempted by a Louisiana
law barring arbitration of insurance disputes pursuant to the McCarran-Ferguson Act.
The district court therefore denied the insurers’ motion to compel arbitration. The Fifth
Circuit reversed.

DECISION

The Fifth Circuit ruled that the district court abused its discretion by failing to compel
arbitration under the Convention pursuant to the equitable estoppel doctrine. The Fifth
Circuit explained that the domestic insurers had a right to compel arbitration under theConvention, despite the fact they were non-signatories to Bufkin’s policies with the foreign
insurers. The court held that equitable estoppel applies where, as here, allegations involve
substantially “interdependent and concerted misconduct by both the non-signatory andone or more of the signatories to the contract.’” More specifically, the court found that
Bufkin alleged “substantially interdependent and concerted misconduct” by the domestic
and foreign insurers because Bufkin submitted its claim to both the foreign and domestic
insurers and its “formal proof of loss ascribed to the insurers, as a group, a common courseof conduct.”
The court deemed it irrelevant that Bufkin was no longer pursuing claims against theforeign insurers, emphasizing that the standard for equitable estoppel was met because
Bufkin “named the foreign insurers as defendants and accused them of the same
malfeasance as the domestic insurers.” The court stated:in focusing on Bufkin’s dismissal of the foreign insurers, the district court
neglected to consider the foreign insurers’ part in the seamless coverage

2agreement struck by the parties, and Bufkin’s interactions with the insurers.
Honing in, that coverage arrangement included the arbitration clause thatafforded the insurers – foreign and domestic – “predictability in resolving
disputes dealing with the substantial risks presented by a surplus lines
insurance policy.”
COMMENTS

The decision highlights an important distinction between motions to compel arbitration
pursuant to the FAA (a domestic “Act of Congress” under the McCarran-Ferguson Act) as
compared to the Convention (an international treaty). Under Fifth Circuit precedent, astate statute that precludes arbitration of insurance disputes (such as the Louisiana law atissue here), reverse preempts the FAA under the McCarran-Ferguson Act, but does notreverse preempt the Convention. As discussed in previous Alerts, federal courts of appeals
are split as to whether a state law barring arbitration of insurance disputes reverse
preempts the Convention pursuant to the McCarran-Ferguson Act. The Fourth, Fifth andNinth Circuit have ruled that there is no reverse preemption of the Convention, whereas
the Second Circuit has allowed reverse preemption under the Convention.

Applying “Meaningfully Linked” Standard, Delaware
Court Rules That Securities Action Is Not “Related” To
Previous SEC Action
HOLDINGA Delaware court ruled that a Securities and Exchange Commission (“SEC”) subpoena anda subsequent securities action were not “meaningfully linked” for purposes of applying an
Interrelated Wrongful Acts provision and a Prior Notice Exclusion in a D&O policy. Alexion
Pharmaceuticals, Inc. v. Endurance Assurance Corp., 2024 Del. Super. LEXIS 103 (Del.
Super. Ct. Feb. 15, 2024).

BACKGROUNDIn March 2015, Alexion, a pharmaceutical company,
received an SEC Order notifying the company of aninvestigation relating to, among other things,
allegedly improper accounting practices, bribes toforeign officials, and matters relating to the recall of adrug called Soliris. In a subpoena issued in May 2015,
the SEC sought documents related to Alexion’s
foreign and domestic grant-related activities, its
compliance with the Foreign Corrupt Practices Act(“FCPA”) and the recall of Soliris. In July 2020,
Alexion settled with the SEC and agreed to remedy
certain areas of noncompliance and pay over $21
million in penalties.
In December 2016, a class of stockholders filed asecurities suit against Alexion and its executives,
alleging that they “overpaid for stock that waspropped up by illegal activity.” The complaint allegedthat the defendants misled investors and violated
ethical standards and federal securities law.

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Alexion sought coverage for the securities action under two towers of insurance: a 20142015 program, and a 2015-2017 program. The operative primary policy in the 2015-1017
program provided that all claims arising out of “Interrelated Wrongful Acts” are deemed to
be one claim—first made on the date the earliest of such claims were made. Additionally, a“Prior Notice Exclusion” barred coverage for any claim attributable to any wrongful act
that was the subject of any written prior notice under that policy or any previous policy forwhich the instant policy was a renewal or replacement.
In ensuing coverage litigation, Alexion moved for summary judgment on the issue of“relatedness,” arguing that the SEC subpoena and the securities action were not related asa matter of law, and therefore that the securities suit “is properly placed in the 2015-2017
coverage tower.” The court granted the motion.
DECISION

The court ruled that the question of relatedness between the SEC subpoena and the
securities action for purposes of applying the Prior Notice Exclusion and the Interrelated
Wrongful Acts provision, is determined by a “meaningful linkage” analysis. The court thenconcluded that there was no meaningful linkage between the two actions.
The court explained that the SEC subpoena was “broadly concerned with Alexion’s
compliance with the FCPA,” and ultimately involved findings related to accounting controls
and payments to foreign officials, whereas the securities action focused on the artificial
inflation of Alexion’s value through various acts of misconduct. The court acknowledgedthat certain alleged activity in Brazil was relevant to both actions, but concluded that
this “tangential link” was insufficient to establish meaningful linkage between the two
actions. Additionally, the court emphasized that the actions involved different parties,
raised “entirely different” theories of liability, relied on different evidence and sought
different relief.

COMMENTSThis decision illustrates the distinction Delaware courts may draw between two actions
being “related” for purposes of applying an Interrelated Wrongful Acts provision or Prior
Notice Exclusion, as opposed to two actions involving “related” evidentiary material. Here,the securities action plaintiffs relied on the SEC findings in arguing that Alexion engaged ina pattern of illegal conduct. Deeming this reliance “unremarkable,” the court stated:“[t]hough accusations of general wrongdoing may lend support to the sweeping allegationsin the Securities Action, such abstract notions are not helpful to a relatedness analysis.”4Texas Supreme Court Rules That Policyholder Suffered
A “Loss” By Virtue Of Underlying Settlement, But That
Settlement Is Not Binding In Coverage Litigation
HOLDING

Granting conditional mandamus relief, the Texas Supreme Court ruled that a policyholder
suffered a covered “loss” because an underlying settlement rendered it “legally obligated topay,” but that the settlement was neither binding nor admissible in related coveragelitigation. In re Illinois National Ins. Co., 2024 Tex. LEXIS 158 (Tex. Feb. 23, 2024).

BACKGROUND

Cobalt, an energy company, was named as a defendant in a federal securities action. A
court appointed a collection of investment funds that held Cobalt shares (“GAMCO”) as
lead plaintiff in the suit. Cobalt’s insurers denied coverage for the claims and refused toadvance defense costs. Cobalt subsequently filed for bankruptcy and settled with GAMCO.
The settlement agreement provided for a “Settlement Amount” of $220 million andincluded an “obligation to satisfy” the amount by Cobalt. However, the parties agreed that
it would be “payable exclusively” from any insurance recoveries and that GAMCO would
pursue all of Cobalt’s claims against its insurers on Cobalt’s behalf. The agreement released
all claims against Cobalt and its executives, regardless of whether GAMCO was able torecover any insurance proceeds, and required that Cobalt deposit $4.2 million that it had
previously received from certain insurers into an escrow account and cooperate withGAMCO in its efforts to obtain insurance coverage.
After a court approved the settlement, GAMCO intervened in a coverage suit between
Cobalt and its insurers. The parties cross-moved for summary judgment on three issues:(1) whether Cobalt suffered a covered “loss”; (2) whether GAMCO had standing to sue
the insurers; and (3) whether the settlement was binding on the insurers or admissible toestablish coverage.
A Texas trial court ruled in GAMCO’s favor and the Texas Supreme Court accepted theinsurer’s petition for mandamus relief.

DECISION

The Texas Supreme Court explained that the first two issues turned on resolution of thesame question: whether Cobalt had a “legal obligation to pay” any sums to any party. As thecourt noted, the relevant policies required a legal obligation to pay in order to establish acovered “loss” and under Texas’s “no-direct-action” rule, an injured party may only sue thewrongdoer’s insurer after it has established that the insured was legally obligated to
pay damages.
The insurers argued that Cobalt was not financially liable to pay GAMCO because thesettlement agreement released Cobalt from any liability and required GAMCO to look solely
to the insurers for recovery. Further, the settlement agreement allowed Cobalt to recover
up to $28.5 million it had spent in defense costs if GAMCO was successful in obtaining
insurance proceeds.
The court rejected these arguments and held that Cobalt was “legally obligated to pay.”
The court noted that Cobalt had already deposited $4.2 million in insurance benefits
into an escrow account and remained “legally obligated” to pay any additional benefits it
might receive. Further, the court emphasized that Cobalt was obligated to fully cooperatein GAMCO’s litigation against the insurers, at its own expense. The court deemed itirrelevant that Cobalt denied liability or wrongdoing in the settlement, reasoning that a5legal obligation to pay does not depend on an admission of liability. Similarly, the court
held that a legal obligation to pay can exist even if Cobalt is not required to pay “from its
own pockets.”
The court acknowledged that Cobalt’s release from any liability “require[d] a slightly
more complicated analysis,” but concluded that the settlement ultimately rendered Cobalt“legally obligated to pay” GAMCO—through both the prior payment and any future
payments to the escrow account. In this context, the court emphasized that if Cobalt
failed to fulfill its obligations to deliver any future recoverable benefits, the release would
be ineffective.
With respect to the third issue, whether the settlement agreement was binding on theinsurers or admissible in a coverage action, the Texas Supreme Court held that thetrial court abused its discretion and granted conditional mandamus relief. The Texas
Supreme Court ruled that the settlement agreement was not binding against the insurers
or admissible to establish coverage for the amount of loss because it did not result froma “fully adversarial trial.” The court based this holding on its finding that Cobalt lacked
the necessary “meaningful incentive” to ensure that the settlement accurately reflected
GAMCO’s damages. The court explained: “the settlement agreement here ‘eliminated any
meaningful incentive’ because GAMCO ‘agreed not to enforce any resulting judgment’and ‘not to pursue’ Cobalt’s non-insurance assets, leaving only the insurance policies ‘as a
potential source to satisfy any judgment obtained.’”COMMENTS

One important element in the court’s decision was the fact that the policies at issue were
“liability” policies rather than “true ‘indemnity’ policies.” A liability policy obligates aninsurer to pay “on behalf of” the insured the amounts that the insured is legally obligated topay. In contrast, under an indemnity policy the insurer agrees to reimburse the insured forthe amounts the insured “has actually paid” to fulfill a legal obligation. The court deemed
this distinction critical in finding that Cobalt was legally obligated to pay, regardless ofwhether it “ever actually pays out of its own coffers first.”

Reversing District Court, First Circuit Rules That Insurer
Is Not Entitled To Recoup Defense Costs Or Settlement
Payments From Insured
HOLDINGThe First Circuit ruled that an insurer is not entitled
to recover costs incurred in defending its insured orin settling an excluded underlying claim. Berkley
National Ins. Co. v. Atlantic-Newport Realty LLC,
93 F.4th 543 (1st Cir. 2024).

BACKGROUND

Berkley National Insurance Company issued aliability policy to Granite Telecommunications that
listed Atlantic-Newport Realty as an additional
insured. When a personal injury suit was filed
against both entities, Berkley agreed to defend
under a reservation of rights. While that suit was
pending, Berkley commenced an action against
Granite and Atlantic-Newport, seeking a declaration6

of no coverage and asserting a claim for restitution based on amounts paid to defend theunderlying suit. The personal injury suit ultimately settled, with Berkley funding thesettlement. Thereafter, Berkley amended its complaint to add a request for restitution of
the settlement payment as well.
A Massachusetts district court denied Granite and Atlantic-Newport’s motion for judgmenton the pleadings. Following discovery, the district court granted Berkley’s summary
judgment motion, ruling that it had no duty to defend or indemnify the underlying suitbased on a policy exclusion, and was entitled to restitution of its defense and indemnity
payments. The First Circuit reversed.
DECISION

The First Circuit held that the district court’s ruling as to restitution of the settlement
payment conflicted with Massachusetts precedent. In Med. Malpractice Joint
Underwriting Assoc. of Mass. v. Goldberg, 425 Mass. 46 (1997), the Supreme Judicial
Court of Massachusetts held that where a policy does not contain a provision forreimbursement of settlement payments by the insurer, an insurer may nonetheless seek
reimbursement only where the following conditions are met:
if the insured has agreed that the insurer may commit the [insurer’s] own
funds to a reasonable settlement with the right later to seek reimbursementfrom the insured, or if the insurer secures specific authority to reach aparticular settlement which the insured agrees to pay.
The district court had concluded that Goldberg was distinguishable from this case because
unlike the insured in Goldberg, Granite and Atlantic-Newport had participated significantlyin the settlement process and had essentially “whipsawed” Berkley into settling. The
First Circuit disagreed, finding Goldberg controlling authority and further holding that
the Goldberg conditions were not met. In this respect, the First Circuit emphasized theundisputed fact that the insureds never agreed to Berkley’s request for reimbursement.
The First Circuit also rejected Berkley’s contention that Goldberg is no longer good law inlight of a subsequent decision that allowed an insurer to bring a restitution claim basedon a reservation of rights that included a right to seek recoupment. The First Circuitemphasized that case involved a disability policy, whereas this case involved a liability
policy, and therefore held that the decision did not conflict with Goldberg.
The First Circuit reached the same conclusion with respect
to Berkley’s claim for restitution of defense costs. The court
reasoned that Berkley’s “full” reservation of rights to disclaim
coverage is not the equivalent of a reservation of the right toseek reimbursement of defense costs, and that there was nobasis in Massachusetts law for allowing a claim for restitutionof defense costs absent any such express reservation.

COMMENTS

As the First Circuit noted, and as we have discussed inprevious Alerts, courts in other jurisdictions have allowed
insurers to seek reimbursement of defenses costs following aruling of no duty to defend, under various circumstances. In
some cases, the court has relied an insurer’s unilateralreservation of right to do so (and the insured’s implicit
agreement to such reservation by accepting the insurer’s
defense) and/or theories of unjust enrichment.

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Sixth Circuit Rules That District Court Erred In
Dismissing Equitable Contribution Claim By Insurer
Against Fellow Insurers Based On Untimely Notice
HOLDING

Reversing an Ohio district court decision, the Sixth Circuit ruled that an insurer’s equitable
contribution claim for reimbursement of pre-tender defense costs from non-defending
insurers should not have been dismissed based on untimely notice alone. ACE AmericanIns. Co. v. Zurich Am. Ins. Co., 2024 U.S. App. LEXIS 5535 (6th Cir. Mar. 5, 2024).

BACKGROUND

Safelite, a windshield repair company, was named as a defendant in a suit alleging Lanham
Act violations. Safelite notified ACE, one of its general liability insurers, but did not notify
Zurich or Discover, two other insurers that had issued general liability policies during therelevant time period. After paying for Safelite’s defense costs for more than a year, ACE
inquired about other liability policies, and approximately two years after ACE beganfunding the defense, notified Zurich and Discover of the underlying suit and its intent toseek equitable contribution from them. Zurich and Discover agreed to equally share future
defense costs with ACE, but refused to reimburse ACE for pre-tender defense costs (i.e.,
defense costs incurred prior to the date they received notice).
An Ohio trial court ruled in favor of Discover and Zurich, concluding that they had no duty
to contribute to past defense costs based on untimely notice, regardless of prejudice. The
Sixth Circuit vacated and remanded the matter for further proceedings.

DECISION

Under Ohio law, a party seeking equitable contribution must show the existence of a sharedobligation, payment by the plaintiff and a failure of the defendant to pay its proportional
share. Since there was no dispute that ACE
had paid prior defense costs, the central issue
was whether Zurich and Discover had ashared obligation for those costs. Resolutionof that issue turned on whether ACE’s
untimely notice of the underlying suit,standing alone, relieved Zurich and Discoverof their defense obligations. The Sixth Circuit
held that it did not.
The Sixth Circuit explained that under Ohiolaw, occurrence-based liability policies
require a showing of prejudice in order for
untimely notice to preclude coverage, and thatthe district court erred in failing to conduct a
prejudice analysis. The Sixth Circuit rejected
Discover’s assertion that its policy did not
require a showing of prejudice because its
notice provision, which required notice
within thirty days rather than a “reasonable”
time, was more akin to a claims-made policy(for which prejudice is not required). The
Sixth Circuit explained that regardless of thethirty-day provision, the policy was still an

8occurrence-based policy based on language limiting coverage to an “offense...committed...
during the policy period.”
The Sixth Circuit remanded the matter to the district court for a fact-intensive prejudiceinquiry in order to determine whether the insurers had a shared defense obligation. The
Sixth Circuit also instructed the district court to consider whether a voluntary payments
provision in Zurich and Discover’s policies eliminated any potential shared obligation.
COMMENTS

While the Sixth Circuit ruled that ACE’s equitable contribution claim should not have been
dismissed, it disagreed with ACE’s assertion that “special notice rules” applied here in lightof Ohio’s endorsement of “all sums” allocation. ACE argued that under the “all sums”
approach, ACE was the “targeted insurer” and acted appropriately by defending Safelite on
its own and then later seeking contribution from other insurers. The court ruled that allsums allocation applies only in progressive injury cases, and was thus irrelevant to thepresent case, which involved “distinct and identifiable events that occurred at a known or
knowable time.”

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

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

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

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

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

Matthew C. Penny+1-212-455-2152
matthew.penny@stblaw.com

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Sarah E. Phillips+1-212-455-2891
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Chet A. Kronenberg+1-310-407-7557
ckronenberg@stblaw.com

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

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

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

This edition of the
Insurance Law Alert was prepared byBryce L. Friedman / +1-212-455-2235
bfriedman@stblaw.com
Laura Lin / +1-650-251-5160
laura.lin@stblaw.com andKaren Cestarikcestari@stblaw.com.

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