Insurance Law Alert

December 2021

In This Issue
Applying Florida Law, Connecticut Court Rules That Primary Insurer
Cannot Recover Defense Costs From Co-Primary Insurer
A Connecticut trial court ruled that Florida law does not permit a primary insurer to recoverdefense costs from another insurer that was also obligated to defend the mutual insured.
Hartford Cas. Ins. Co. v. XL Ins. Am., Inc., 2021 WL 5112993 (Ct. Super. Ct. Oct. 21, 2021).
(Click here for full article)

Simpson Thacher
Names Lynn K. Neuner
Co-Chair of Global
Litigation Department-Click here to learn more

Oklahoma Supreme Court Rules That Pollution Exclusion Is Ambiguous
In The Context Of Earthquake Damage, But That Earth Movement
Exclusion Unambiguously Bars Coverage
The Supreme Court of Oklahoma ruled that a total pollution exclusion was ambiguous as
to whether it barred coverage for earthquake-related claims but that an earth movement
exclusion squarely applied to preclude coverage. National Am. Ins. Co. v. New Dominion, LLC,
2021 WL 5459471 (Okla. Nov. 23, 2021). (Click here for full article)

Seventh Circuit Affirms Dismissal Of Four Suits Seeking Coverage For
Pandemic-Related Losses
This month, the Seventh Circuit dismissed four policyholder suits seeking coverage forbusiness losses incurred in the wake of government shutdowns aimed at slowing the spread of
COVID-19. Sandy Point Dental, P.C. v. Cincinnati Ins. Co., 2021 WL 5833525 (7th Cir. Dec. 9,2021); Crescent Plaza Hotel Owner, L.P. v. Zurich Am. Ins. Co., 2021 WL 5833485 (7th Cir.
Dec. 9, 2021); Bradley Hotel Corp. v. Aspen Specialty Ins. Co., 2021 WL 5833486 (7th Cir.
Dec. 9, 2021); Mashallah, Inc. v. West Bend Mutual Ins. Co., 2021 WL 5833488 (7th Cir. Dec.
9, 2021). (Click here for full article)

Two Ohio Appellate Courts Affirm Dismissals Of COVID-19 Coverage Suits
Appellate courts in two Ohio districts affirmed the dismissal of policyholder suits seeking
business interruption coverage in the wake of government-mandated shutdowns. Nail Nook,
Inc. v Hiscox Ins. Co. Inc., 2021 WL 5709971 (Ohio Ct. App. 8th Dist. Dec. 2, 2021); Sanzo
Enterprises, LLC v. Erie Ins. Exchange, 2021 WL 5816448 (Ohio Ct. App. 5th Dist. Dec. 7,2021). (Click here for full article)


Simpson Thacher & Bartlett LLP

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Two New York Courts Rule On COVID-19 Coverage Suits, Reaching
Different Results
One New York trial court denied an insurer’s motion to dismiss a COVID-19-related coverage
suit, finding that a communicable disease exclusion did not bar coverage, Tina Turner Musical
LLC v. Chubb Ins. Co. of Europe SE, 2021 WL 5818352 (N.Y. Sup. Ct. Dec. 6, 2021), whereasanother granted an insurer’s motion to dismiss based on the absence of direct physical loss ordamage, Buffalo Bills, LLC v. American Guarantee and Liability Ins. Co., 2021 WL 5863939(N.Y. Sup. Ct. Dec. 7, 2021). (Click here for full article)

After Allowing Submission Of Expert Testimony, Indiana Court Dismisses
Business Interruption Coverage Claims
An Indiana state court granted an insurer’s summary judgment motion, ruling that expert
testimony offered by the policyholder failed to raise a triable issue of fact as to the availabilityof business interruption coverage for COVID-19-related losses. Indiana Repertory Theatre,Inc. v. Cincinnati Cas. Co., No. 49D01-2004-PL-013137 (Ind. Super. Ct. Dec. 13, 2021).
(Click here for full article)

Florida Court Rules That Professional Services Exclusion Does Not
Relieve Insurer Of Duty To Defend
A Florida district court ruled that an insurer was obligated to defend a professional women’s
tennis organization in an underlying arbitration alleging injury stemming from drug testing
requirements, finding that the organization’s enforcement of drug testing regulations was not a“professional service” under the policy exclusion. Depositors Ins. Co. v. WTA Tour, Inc., 2021
WL 5908833 (M.D. Fla. Dec. 14, 2021). (Click here for full article)

STB News Alert
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2Reimbursement
Alert:
Applying Florida Law, Connecticut
Court Rules That Primary Insurer
Cannot Recover Defense Costs
From Co-Primary Insurer
A Connecticut trial court ruled that Florida
law does not permit a primary insurer torecover defense costs from another insurerthat was also obligated to defend the mutual
insured. Hartford Cas. Ins. Co. v. XL Ins.
Am., Inc., 2021 WL 5112993 (Ct. Super. Ct.
Oct. 21, 2021).
MCM, the general contractor for theconstruction of a pedestrian bridge in Florida,
was insured under a general liability policy
issued by Greenwich. MCM was also listed as
an additional insured under a policy issued
by Hartford to a subcontractor involvedin the project. When the bridge collapsed,
lawsuits were filed against MCM andothers. Greenwich agreed to defend MCM
and thereafter sought reimbursement of$6 million in defense costs from Hartford.
In ensuing litigation, both insurers moved
for summary judgment. The court ruledin Hartford’s favor, finding that it had no
duty to reimburse Greenwich for amounts
Greenwich incurred in defending MCM in theunderlying lawsuits.
The insurers’ summary judgment motions
centered on whether the underlying
allegations gave rise to additional insured
coverage for MCM under Hartford’s policy.
However, the court declined to address those
substantive coverage arguments, insteadruling as a threshold matter that “Florida law
is clear that an insurer cannot recover fromanother insurer costs incurred in defending amutual insured.”
Greenwich argued that this rule of law did
not apply because its policy provided excess
coverage whereas Hartford’s coverage
was primary. The court ruled that evenassuming that Greenwich’s policy wasexcess to Hartford, Greenwich’s claim forreimbursement would nonetheless failbecause Greenwich also provided primary
coverage to MCM under a different policy
issued to another MCM subcontractor. The
court explained that both the Hartford policy
listing MCM as an additional insured andthe other Greenwich policy listing MCM
as an additional insured contained “Other
Insurance” provisions purporting to makeeach policy excess to the other. The court heldthat these polices “cancel each other out,”
rendering both insurers primary to MCM asa mutual insured. Based on the co-primarystatus, the court concluded that Florida lawbars Greenwich from seeking reimbursementof defense costs from Hartford.

Coverage Alert:
Oklahoma Supreme Court Rules
That Pollution Exclusion Is
Ambiguous In The Context Of
Earthquake Damage, But That
Earth Movement Exclusion
Unambiguously Bars Coverage
The Supreme Court of Oklahoma ruled thata total pollution exclusion was ambiguous as
to whether it barred coverage for earthquakerelated claims but that an earth movement
exclusion squarely applied to preclude
coverage. National Am. Ins. Co. v. New
Dominion, LLC, 2021 WL 5459471 (Okla.
Nov. 23, 2021).
A series of lawsuits against New Dominion
alleged personal injury and property damage
as a result of seismic activity allegedly caused
by New Dominion’s oil and gas operations.
Its insurer denied coverage on the basis of
exclusions for pollution and earth movement.
The Oklahoma Supreme Court ruled thatwhile the pollution exclusions in several
consecutive policies did not clearly andunambiguously preclude coverage, the earth
movement exclusions did.
The pollution exclusion in each policy definedpollutants as “any solid, liquid, gaseous or3thermal irritant or contaminant.” The court
held that the terms “irritant or contaminant”
were ambiguous as to whether the exclusion
applied only when the injury or damage forwhich coverage was sought arose out of theirritating or contaminating nature of thepollutant, or whether it applied even when
the injury was not the result of the harmful
nature of the substance. The court reasoned
that while wastewater is clearly a contaminantor irritant, the underlying claims alleged
harm based on the injection of wastewater
into the land in a manner that caused seismic
activity—not on the contaminating qualitiesof the wastewater. The court explained:“[T]he substance being injected into theground could have been something more
innocuous, such as fresh, potable water, andthe result would have been the same.” Having
determined that the pollution exclusion
was ambiguous, the court held that it was
reasonable for New Dominion to understandthe pollution exclusion to apply only wheninjury or damage resulted from the irritatingor contaminating nature of a pollutant.

However, the court ruled that an earth
movement exclusion in each policy (thelanguage of which differed slightly across thepolicies) unambiguously barred coverage.
In the first two policy periods, the exclusion
barred coverage for damage “whether direct
or indirect, arising out of, caused by, resulting
from, contributed to, or aggravated by thesubsidence, settling, expansion, sinking,slipping, falling away, tilting, caving in,
shifting, eroding, mud flow, rising or any
other movement of land or earth.” In thesecond two policy periods, the exclusion
language also included “earthquake” inthe list of events for which there would
be no coverage. New Dominion argued
that omission of the term “earthquake”
in the first two policies created ambiguity

as to the applicability of the exclusions in
those periods.
Rejecting this assertion, the court ruledthat the exclusion in each policy “muststand independently” and that extrinsic
evidence from other policy periods should
not be considered in evaluating ambiguity.
The court concluded that the exclusion in
the first two policy periods unambiguously
barred coverage for the events alleged in
the underlying complaints because the listof excluded events included “nearly every
event that is commonly associated withan earthquake.”
Finally, the court rejected New Dominion’s
estoppel claims. The company argued that theinsurer was estopped from denying coveragefor the third policy based on statements madeto New Dominion by its insurance agent and asenior claims manager at National American
Insurance regarding earthquake coverage.
The court explained New Dominion would
be unable to establish reliance for statements
made after renewal of the third policy andthat statements made prior to the renewal
did not provide any “definitive answers”
on the question of earthquake coverage.
Regarding the fourth policy, the court
held that New Dominion was charged withconstructive knowledge of the exclusionary
language, which clearly and unambiguously
contradicted any statements that theinsurance agent and claims manager might
have made.

COVID-19 Alerts:
Seventh Circuit Affirms Dismissal
Of Four Suits Seeking Coverage For
Pandemic-Related Losses
This month, the Seventh Circuit dismissedfour policyholder suits seeking coveragefor business losses incurred in the wake ofgovernment shutdowns aimed at slowing the
spread of COVID-19. The Seventh Circuitis the fifth federal appellate court to rule ininsurers’ favor in such suits.
In Sandy Point Dental, P.C. v. Cincinnati
Ins. Co., 2021 WL 5833525 (7th Cir. Dec.
9, 2021), a consolidated opinion resolving
three separate appeals, the Seventh Circuit
ruled that a dental group and hotel operators
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failed to allege direct physical loss or damage
to property and were therefore not entitled
to coverage under Cincinnati’s commercial
property policies.
Noting the absence of state law precedent,
the court predicted that the Illinois Supreme
Court would not find that a loss of useof property sufficed to meet the “direct
physical loss” policy requirement. The
court emphasized that the policies were“replete with textual clues that reinforce theconclusion that ‘direct physical loss’ requires
a physical alteration to property,” such as
clauses referring to “restoration” of property.

The policyholders alleged that the virus
rendered the property unsafe or unfit for its
intended use and therefore caused physicalproperty damage. The court ruled thatthese allegations were insufficient to allege
direct physical loss, emphasizing that thepolicyholders were able to perform somebusiness operations during the shutdown
period. The court also ruled that amending
the complaint would be futile because even
if the policyholder alleged that the virus
was present and physically attached itself
to surfaces, the complaint would still failto allege that the virus altered the physicalstructures to which it attached.
The court distinguished decisions in which
courts ruled that the presence of othersubstances at insured property (e.g., asbestosor harmful gas) satisfied the physical loss
requirement, noting that those cases “led tomore than a diminished ability to use theproperty.” The court explained that in thosecases, “the contamination made the premises‘uninhabitable’ or ‘unfit for normal humanoccupancy’ . . . thus barring all uses by all
persons.” In the COVID-19 context, however,the policyholders’ preferred uses of insured
premises were “partially limited” at most.
In two other decisions, the Seventh Circuit
affirmed dismissal of coverage suits based on
the reasoning set forth in Sandy Point, butalso held that policy exclusions provided asecond basis for dismissal. In Cresent Plaza
Hotel Owner, L.P. v. Zurich Am. Ins. Co.,
2021 WL 5833485 (7th Cir. Dec. 9, 2021), thecourt also held that coverage was unavailable
based on a microorganism exclusion. The
exclusion applied to loss “directly or indirectly
arising out of or relating to: mold, mildew,
fungus, spores or other microorganism of any
type, nature, or description, including but
not limited to any substance whose presence
poses an actual or potential threat to humanhealth.” The court ruled that the exclusion
was unambiguous and that the virus qualified
as a microorganism. In so ruling, the court
noted the broad exclusionary language (“ofany type, nature or description”) and its
application to any substance that poses a
potential threat to health. The court rejected
the assertion that the inclusion of a specificcommunicable disease exclusion in a later
policy amounted to a “tacit admission” thatthe policy at issue did not exclude losses
caused by viruses.
Similarly, in Bradley Hotel Corp. v. Aspen
Specialty Ins. Co., 2021 WL 5833486 (7th Cir.
Dec. 9, 2021), the court held that exclusions
relating to “loss of use” and “ordinanceor law” provided independent bases for
upholding coverage denials, separate andapart from the Sandy Point reasoning. One
exclusion barred coverage for loss or damage
caused by “[d]elay, loss of use or loss ofmarket.” The other applied to loss caused
directly or indirectly from “[t]he enforcementof or compliance with any ordinance orlaw: (1) Regulating the construction, use or
repair of any property.” The court concluded
that both exclusions applied, noting thatthe insured hotel’s COVID-19-related losses
stemmed precisely from “loss of use” andthat the local executive closure orders were“ordinances” or “laws” that regulated the“use” of property. Declining to address the“difficult and esoteric” question of what
actions qualify as “law” in the abstract, thecourt explained that the “executive orders
here had the force of law and could be
enforced with coercive sanctions against
private businesses and persons.”5

Finally, in Mashallah, Inc. v. West Bend
Mutual Ins. Co., 2021 WL 5833488 (7th Cir.
Dec. 9, 2021), the Seventh Circuit upheld
dismissal of a COVID-19-related coverage
suit involving two policies based on virus
exclusions. One policy barred coverage forloss or damage “caused directly or indirectly”
by “[a]ny virus . . .that induces or is capable ofinducing physical distress, illness or disease.”
The exclusion in the other included similar
language, but omitted the phrase “directly
or indirectly.” The district court bypassed
the issue of whether the complaints alleged
direct physical loss or damage, ruling thatthe exclusions foreclosed any possibilityof coverage.
On appeal, the Seventh Circuit rejected thepolicyholders’ argument that the losses werecaused by the orders rather than the virus,
stating:
The complaint’s attempt to decouple thegovernment COVID-19 orders from the
COVID-19 virus itself [is] untenable. . . .
[T]here can be no honest dispute that thecoronavirus was the reason these orders
were promulgated. It was, so to speak,
the prime mover. The causal relationshipbetween the novel coronavirus, the
COVID-19 pandemic, the government
orders, and the alleged losses andexpenses “is not debatable.”
The court also rejected the assertion thatthe virus must be physically present on theinsured property in order for the exclusion to
apply, noting that the policy language did notsupport such an interpretation.

Two Ohio Appellate Courts Affirm
Dismissals Of COVID-19 Coverage
Suits
This month, appellate courts in two Ohio
districts affirmed the dismissal of policyholder
suits seeking business interruption
coverage in the wake of governmentmandated shutdowns.
In Nail Nook, Inc. v Hiscox Ins. Co. Inc., 2021
WL 5709971 (Ohio Ct. App. 8th Dist. Dec. 2,2021), the court ruled that a virus or bacteria
exclusion unambiguously barred coveragefor the policyholder’s losses. The exclusion
applied to loss or damage caused directly or
indirectly by “[a]ny virus, bacterium or othermicroorganism that induces or is capable ofinducing physical distress, illness or disease.”
Alternatively, the court noted that even absent
the virus exclusion, the policyholder’s claims
would fail because the complaint did notallege “direct physical loss of or damage” toinsured property.

Similarly, in Sanzo Enterprises, LLC v. ErieIns. Exchange, 2021 WL 5816448 (Ohio Ct.
App. 5th Dist. Dec. 7, 2021), the court heldthat the phrase “direct physical loss of ordamage to property” in an insurance contract
does not cover the loss of use of a property
caused by government shutdown orders.
Rather, “the plain and ordinary meaning of
the phrase ‘direct physical loss of or damage
to’ unambiguously requires a tangible andstructural damage to the property.” Because
the policyholder’s property “exists in the samestate as it did before the Orders,” the court
held that there was no physical loss. The court
noted that even if the policyholder allegedthat the virus was physically present on its
premises, coverage would still be unavailable
because the virus would not cause damage
that required repair or restoration.
Additionally, the court found that the absenceof a virus exclusion was not material to thecoverage analysis. The court explained:“Because appellant cannot establish its initialentitlement to coverage, we need not consider
the impact of the lack of a virus exclusion.”
Finally, the court ruled that a civil authority
provision did not apply. The court reasoned
that the government orders were issued
to prevent the spread of the virus, not in
response to any damage to other property.

Two New York Courts Rule On
COVID-19 Coverage Suits, Reaching
Different Results
A New York trial court denied an insurer’s
motion to dismiss a COVID-19-related
6

coverage suit, finding that a communicabledisease exclusion did not bar coverage. Tina
Turner Musical LLC v. Chubb Ins. Co. ofEurope SE, 2021 WL 5818352 (N.Y. Sup. Ct.
Dec. 6, 2021).

availability of business interruption coverage
for COVID-19-related losses. Indiana
Repertory Theatre, Inc. v. Cincinnati Cas.
Co., No. 49D01-2004-PL-013137 (Ind. Super.
Ct. Dec. 13, 2021).

The exclusion precluded coverage for “anycommunicable disease or threat or fear ofcommunicable disease (whether actual or
perceived) which leads to: . . . the impositionof quarantine or restriction in movementof people or animals by any national orinternational body [or] . . . any travel advisory
or warning being issued by a national orinternational body or agency.” The court ruledthat this provision did not apply because thepolicyholder’s losses stemmed from an orderissued by the New York Governor rather thana national or international authority.

The policyholder alleged that the virus
was present at its theater and therefore
contaminated and “physically alteredor damaged” the air and property at thepremises. In support of this allegation, thepolicyholder’s expert provided statisticalmodeling indicating that for an average
audience of attendees, an average of 2.2
individuals would be infected with COVID-19.

In a different matter, a New York trial court
granted an insurer’s motion to dismiss a
COVID-19-related coverage suit. Buffalo Bills,
LLC v. American Guarantee and Liability
Ins. Co., 2021 WL 5863939 (N.Y. Sup. Ct.
Dec. 7, 2021). There, a professional footballteam argued that it incurred “direct physicalloss or damage” to property based on the lossof use of its stadium and the “alter[ation][of] the structure of ambient air and Covered
Property’s surfaces.” In response, the insurer
contended that the policyholder’s loss was
economic rather than physical, based on
the temporary nature of the viral presence,
among other things.

After Allowing Submission Of
Expert Testimony, Indiana Court
Dismisses Business Interruption
Coverage Claims
An Indiana state court granted an insurer’ssummary judgment motion, ruling thatexpert testimony offered by the policyholder
failed to raise a triable issue of fact as to the

The court ruled that the expert’s statisticalmodeling raised a genuine issue of material
fact as to the presence of the virus at theinsured premises, rejecting the insurer’s
contention that the evidence was based on“speculation” and “guesswork.” However,the court nonetheless ruled that coverage
was unavailable based on its finding that thevirus is not capable of physically altering or
damaging property. The court emphasizedthat the virus can be removed by cleaning
and that it dies over time, stating that under
the policyholder’s argument, “any time an
undesirable substance or thing were to entera room, no matter how fleetingly, property
insurance could be implicated. That is an
unreasonable and boundless extension ofproperty insurance.”

Professional
Services Alert:
Florida Court Rules That
Professional Services Exclusion
Does Not Relieve Insurer Of Duty
To Defend
A Florida district court ruled that an insurer
was obligated to defend a professional
women’s tennis organization in an underlying
arbitration alleging injury stemming fromdrug testing requirements, finding that theorganization’s enforcement of drug testing
regulations was not a “professional service”
under the policy exclusion. Depositors Ins.
Co. v. WTA Tour, Inc., 2021 WL 5908833(M.D. Fla. Dec. 14, 2021).

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A tennis player sued the WTA, the governing
body for professional women’s tennis,
alleging negligence, battery, and intentional
infliction of emotional distress, among otherclaims. The suit claimed that the player
suffered from a medical condition thatcaused her to experience severe pain andswelling from blood draws, and that her
requests for medical accommodations withrespect to drug testing prior to matches wereignored. The insurer sought a declarationthat it had no duty to defend the claims
based on a professional services exclusion.
The court disagreed and ruled in thepolicyholder’s favor.

a “professional service.” The court stated:“[E]ven if Brengle’s claims do ‘arise out of’the venipuncture, they also arise in partfrom business decisions made by the WTA toenforce its policies. Such business decisions
fall outside the Exclusion.” The court further
reasoned that requiring an athlete to submit
to drug testing is not, itself, a professional
service because it “does not involve the useof, or failure to use, any professional skill,
knowledge, experience or training.”

The exclusion applied to any “[m]edical,
surgical, psychiatric, chiropractic, chiropody,
physiotherapy, osteopathy, acupuncture,dental, x-ray, nursing or any other healthservice, treatment, advice, or instruction.”
The court acknowledged that the drawing ofblood is a medical service within the meaningof the exclusion, but held that the WTA’s
decision to enforce its regulations mandating
drug testing is a business decision rather than

Joshua Polster and Associate Conor
Mercadante authored an article titled, “BIPA
Ruling Should Aid Insurers In Privacy
Claims” which was published by Law360.
The article examines the Illinois Biometric
Information Privacy Act that has resulted
in substantial litigation against companies
that collect biometric information, and, inturn, has led to disputes regarding insurance
coverage for such claims.

STB News Alert

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

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

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

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

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

George S. Wang
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gwang@stblaw.com

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

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

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

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

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

Isaac M. Rethy+1-212-455-3869
irethy@stblaw.com

This edition of the Insurance Law
Alert was prepared by
Mary Beth Forshaw / +1-212-455-2846
mforshaw@stblaw.com andAndrew T. Frankel / +1-212-455-3073
afrankel@stblaw.com
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
or matters, nor does the distribution of this publication to any person constitute the establishment of an
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