Insurance Law Alert

September 2017

In This Issue
Michigan Court Rules That Fraudulent Wire Transfer Losses Are Not
Covered By Liability Policy
A Michigan federal district court ruled that a policyholder is not entitled to coverage for losses
arising from a wire transfer initiated by a fraudulent email. American Tooling Center, Inc. v.
Travelers Cas. & Sur. Co. of Am., 2017 WL 3263356 (E.D. Mich. Aug. 1, 2017). (Click here forfull article)

Simpson Thacher
is “always responsive
and provides on-point
legal analysis” and “it has
the brightest and mosttalented team around.”–The Legal 500 2017,
quoting a client

California Appellate Court Rejects Policyholder’s Attempt To “Electively
Stack” Excess Policies
A California appellate court ruled that a policyholder is not entitled to electively stack excess
policies issued in a single policy year, finding that the policyholder’s elective vertical exhaustion
approach is not supported by policy language or common law. Montrose Chemical Corp. of Ca.
v. Superior Court of the State of Ca., 2017 WL 3772568 (Ca. Ct. App. Aug. 31, 2017). (Click here
for full article)

Eighth Circuit Rules That Policyholder’s Failure To Allocate Settlement
Between Covered And Non-Covered Claims Is Fatal To Suit Against
Insurers
The Eighth Circuit ruled that excess insurers have no obligation to indemnify a policyholder’s
underlying lump sum settlement of two underlying suits, only one of which was potentiallycovered by the policies. UnitedHealth Grp. Inc. v. Executive Risk Specialty Ins. Co., 2017 WL
3910115 (8th Cir. Sept. 7, 2017). (Click here for full article)

Florida Appellate Court Rules That Insurer Cannot Assert Defense Based
On Insured’s Failure To Comply With Conditions Precedent After Blanket
Coverage Denial
A Florida appellate court ruled that an insurer that denies coverage based on its determinationthat there is no covered loss cannot later assert that the insured failed to comply with thepolicy’s conditions precedent. Castro v. Homeowners Choice Prop. & Cas. Ins. Co., 2017 WL
3614102 (Ct. App. Fla. 2d Dist. Aug. 23, 2017). (Click here for full article)

Connecticut Supreme Court Rules That Trial Court Improperly VacatedArbitration Award
The Connecticut Supreme Court ruled that a trial court improperly vacated an arbitration
award by substituting its own judgment for that of the arbitration panel. Kellogg v. Middlesex
Mutual Assurance Co., 2017 WL 3526616 (Conn. Aug. 1, 2017). (Click here for full article)
Simpson Thacher & Bartlett LLP

1

Ninth Circuit Rules That “Right To Privacy” Exclusion Relieves Insurer Of
Duty To Defend TCPA Suit
The Ninth Circuit ruled that an insurer is not obligated to defend a Telephone Consumer
Protection Act suit against the Los Angeles Lakers based on a policy exclusion barring coveragefor “right to privacy” claims. Los Angeles Lakers, Inc. v. Federal Ins. Co., 2017 WL 3613340(9th Cir. Aug. 23, 2017). (Click here for full article)

Fifth Circuit Rules That Pollution Exclusion Encompasses Asbestos Claims
Addressing a matter of first impression under Texas law, the Fifth Circuit ruled that asbestos
is a “pollutant” within the meaning of a pollution exclusion. Longhorn Gasket & Supply Co.
v. United States Fire Ins. Co., 2017 WL 3588304 (5th Cir. Aug. 18, 2017). (Click here forfull article)

Pollution Exclusion May Not Bar Coverage For Claims Arising From Oil
Leak, Says New Jersey Court
A New Jersey federal district court denied an insurer’s summary judgment motion, finding thata pollution exclusion does not necessarily bar coverage for contamination claims stemmingfrom an oil leak. Benjamin v. State Farm Ins. Co., 2017 WL 3535023 (D.N.J. Aug. 17, 2017).
(Click here for full article)

Texas Appellate Court Rules That Automobile Policy Does Not CoverPunitive Damages
Distinguishing prior case law, a Texas appellate court ruled that an automobile policy does notprovide coverage for punitive damages. Farmers Texas Cnty. Mutual Ins. Co. v. Zuniga, 2017
WL 4014644 (Tex. Ct. App. Sept. 13, 2017). (Click here for full article)

Oregon Appellate Court Rules That Contribution Claims Are Barred By
State Statute
The Court of Appeals of Oregon ruled that state statutory law precludes contribution claims
between insurers for payments made in connection with underlying environmental claims.
Certain Underwriters at Lloyd’s London v. Mass. Bonding & Ins. Co., 287 Or. App. 279 (Or.
App. Aug. 16, 2017). (Click here for full article)

2Computer Fraud
Coverage Alert:

Michigan Court Rules That
Fraudulent Wire Transfer Losses
Are Not Covered By Liability Policy
As discussed in our July/August 2017 Alert,
several courts have recently rejected
policyholder attempts to obtain coverage forcyber-related losses under computer fraud
and similar policy provisions. Last month, aMichigan federal district court followed suit,
finding that a policyholder is not entitled
to coverage for losses arising from a wiretransfer initiated by a fraudulent email.
American Tooling Center, Inc. v. Travelers
Cas. & Sur. Co. of Am., 2017 WL 3263356(E.D. Mich. Aug. 1, 2017).

as “the use of any computer to fraudulently
cause a transfer” of money or other property
to a third party. The court held that ATC did
not suffer a “direct loss” that was “directly
caused” by “the use of any computer.” Thecourt reasoned that the loss was not “directly
caused” by the fraudulent email because there
were intervening events between receiptof the email and the transfer of funds. In
particular, the court noted that ATC verified
certain product milestones and authorized
the wire transfer but failed to verify the newbank information. The court concluded thatthese intervening events preclude a findingof “direct” loss “directly caused” by the use of
a computer.
Notably, a New York federal district court,
faced with a similar factual record, recently
concluded that claims arising out of losses
caused by a fraudulent wire transfer werecovered by “computer fraud” and “funds
transfer fraud” provisions. See Medidata
Solutions, Inc. v. Federal Ins. Co., 2017 WL
3268529 (S.D.N.Y. July 21, 2017) (discussed
in our July/August 2017 Alert).

Excess Alert:

California Appellate Court
Rejects Policyholder’s Attempt To“Electively Stack” Excess Policies

ATC, a tool and die manufacturer, outsources
work to Shanghai, an overseas manufacturer.
Shanghai receives payment after it sends
an invoice to ATC and the invoice is verified
by ATC. In 2015, ATC received an email
purportedly sent by Shanghai (but in actuality
sent by a third party using a similar domain),
instructing ATC to send payment for several
outstanding invoices to a new bank account.
In response, ATC wired approximately$800,000 to the account without verifying
the new instructions with Shanghai. ATCsought coverage for the loss from Travelers,
which denied the claim. In ensuing litigation,a Michigan court ruled that the policy does
not cover the losses.
Travelers’ policy covers the “direct loss of, ordirect loss from damage to, Money, Securities
and Other Property directly caused byComputer Fraud.” Computer Fraud is defined

A California appellate court ruled that apolicyholder may not electively stack excess
policies issued in a single policy year, findingthat the policyholder’s elective verticalexhaustion approach is not supported bypolicy language or common law. Montrose
Chemical Corp. of Ca. v. Superior Court of
the State of Ca., 2017 WL 3772568 (Ca. Ct.
App. Aug. 31, 2017).
Montrose, a DDT manufacturer, purchased
layers of primary and excess liability policies
from various insurers over a twenty-six year
period. The number of layers and policy
limits of each layer varied from year to year.
In seeking coverage for underlying claims
against it from its excess insurers, Montroseargued that it could select any policy toindemnify its liabilities, and need only show
it had sufficient liabilities to exhaust theunderlying policies in that particular policy
period in order to access excess policies forthe same period (i.e., vertical exhaustion).
3

In contrast, certain insurers argued that
Montrose must exhaust all lower-lying excess
policies in all triggered policy years (i.e.,horizontal exhaustion) before any particularexcess policy could be reached. Ruling on
cross-motions for summary judgment, aCalifornia trial court denied Montrose’s
motion and granted the insurers’ motion.
The trial court held that California law
requires horizontal exhaustion unless policy
language specifically provides otherwise, andthat “other insurance” clauses in the excess
policies preclude vertical exhaustion (evenwhere excess policies explicitly referenced
exhaustion of a particular underlying policy).
The appellate court affirmed in part andreversed in part.
The appellate court ruled that Montrose’s“elective stacking” is not supported bycommon law or policy language. In particular,
the court deemed State v. Continental Ins.
Co., 55 Cal. 4th 186 (2012) (in which thecourt applied “all sums” allocation andallowed stacking) inapplicable, noting thatboth the policy language and legal issues
presented in that case are distinguishable
from the present case. The court expressly
held that Continental does not stand forthe proposition that insureds covered bymultiple policies are entitled to select which
policies to access “in the manner they deem
most efficient and advantageous.” Rather,
the court explained, Continental reinforces
the principle that policy language dictatesissues of allocation and exhaustion. The court
further held that here, policy language does
not allow elective stacking because, among
other things, many excess policies attach only
upon exhaustion of all underlying insurance.
However, the appellate court ruled that thetrial court erred in granting the insurers’
summary judgment motion and holding thatall underlying limits across years of damage
must be exhausted before any excess policy
is triggered. Highlighting the “tremendous
variation among the terms of the excess
policies,” the appellate court held that it could
not conclude, as a matter of law, that every
excess policy requires horizontal exhaustion.
Remanding the matter, the court notedthat “the sequence in which policies may beaccessed must be decided on a policy-bypolicy basis, taking into account the relevant
portions of each policy.”

Settlement Alert:

Eighth Circuit Rules That
Policyholder’s Failure To Allocate
Settlement Between Covered And
Non-Covered Claims Is Fatal To Suit
Against Insurers
The Eighth Circuit ruled that excess
insurers have no obligation to indemnifya policyholder’s lump sum settlement of
two underlying suits, only one of which
was potentially covered by the policies.
UnitedHealth Grp. Inc. v. Executive Risk
Specialty Ins. Co., 2017 WL 3910115 (8th Cir.
Sept. 7, 2017).
UnitedHealth settled two underlying suitswith a single lump-sum settlement. Only
one of the suits was potentially coveredby UnitedHealth’s excess liability policies.
UnitedHealth sued its insurers seeking
indemnity for the settlement and defense
costs for one of the suits. A Minnesota federal
district court ruled in the insurers’ favor. The
court held that UnitedHealth failed to meet its
burden of allocating the settlement between
potentially covered and non-covered claims.
The Eighth Circuit affirmed.
Addressing this matter of first impression
under Minnesota law, the court held that
UnitedHealth bears the burden of allocating
between covered and non-covered claims.
The court further held that it is insufficient for
UnitedHealth “to show simply that its $350
million settlement included a covered claimof an unspecified amount.” Rather, it must
allocate between potentially covered and noncovered claims “with enough specificity topermit a reasoned judgment about liability.”
The court concluded that UnitedHealthfailed to meet this standard, explaining that
evidence relating to pre-settlement rulingsand expert testimony about the value of eachsuit failed to provide “more than a speculativebasis” on which to allocate the settlement.

4

Coverage Alert:

Florida Appellate Court Rules That
Insurer Cannot Assert Defense
Based On Insured’s Failure To
Comply With Conditions Precedent
After Blanket Coverage Denial
A Florida appellate court ruled that aninsurer that denies coverage based on its
determination that there is no covered loss
cannot later assert that the insured failed tocomply with the policy’s conditions precedent.
Castro v. Homeowners Choice Prop. & Cas.
Ins. Co., 2017 WL 3614102 (Ct. App. Fla. 2dDist. Aug. 23, 2017).
Homeowners sought coverage for damage
that appeared to be sinkhole-related. The
property insurer retained an engineering firm
to investigate the claim and subsequently
denied coverage based on an earth movement
exclusion. Prior to the denial, the insurer
did not request examinations under oath(“EUO”), proof of loss or other documentation
relating to the damage. Four years later, thehomeowners asked the insurer to reconsider
its denial based on an engineering reportwhich found that the damage was caused bysinkhole activity. In response, the insurer
requested EUOs and sworn proof of loss. Afterseveral unsuccessful attempts to schedule
the EUOs, the homeowners brought suit.
The insurer moved for summary judgment
based on the homeowners’ refusal to comply
with its demands for EUOs and proof of loss.
A Florida trial court granted the insurer’s
motion, finding that the claim had been“reopened” by the new information and thatthe insurer was entitled to seek compliancewith the policy’s conditions precedent. The
appellate court reversed.
The court ruled that where, as here, aninsurer investigates a claim and denies
coverage based on a determination that nocovered loss has occurred, it cannot later
assert the insured’s failure to comply withconditions precedent as a basis for summary
judgment. The court rejected the insurer’s
assertion that the subsequent submission ofan engineering report constituted a reopeningof the claim “that somehow nullified its
previous denial of coverage.”

Arbitration Alert:

Connecticut Supreme Court Rules
That Trial Court Improperly
Vacated Arbitration Award
The Connecticut Supreme Court ruled that a
trial court improperly vacated an arbitration
award by substituting its own judgment
for that of the arbitration panel. Kellogg v.
Middlesex Mutual Assurance Co., 2017 WL
3526616 (Conn. Aug. 1, 2017).
The dispute arose out of coverage for property
damage under a “restorationist” insurance
policy. Pursuant to the policy’s appraisal
provision, the parties arbitrated a loss
valuation dispute. A three-member panel
awarded the homeowner approximately$460,000, which reflected replacement/
restoration costs less depreciation. The
homeowner moved to vacate the award on thebasis that it was defective under Connecticut

General Statutes § 52-418. The insurer
moved to dismiss. Following a trial on boththe motion to dismiss and the merits of theapplication to vacate, a Connecticut trial court
denied the motion to dismiss and vacated theaward. The court held that the award violated§ 52-418 for two reasons: (1) it prejudiced
the homeowner’s “substantial monetary
rights” because the award was too low, and(2) the award resulted from the panel’s“manifest disregard” of the terms of theinsurance policy. The Connecticut Supreme
Court reversed.
Section 52-418(3) provides that an arbitration
award shall be vacated if the arbitrators havebeen guilty of “any other action by which therights of any party have been prejudiced.”
The Connecticut Supreme Court explainedthat this provision applies only to issues of5

to the team during a game. Federal refused
to defend the suit based on a policy exclusion
for claims “based upon, arising from, or inconsequence of . . . invasion of privacy.” The
Lakers filed suit, and a California district
court dismissed the action based on thepolicy exclusion. The trial court reasoned that
although the underlying suit did not allege
any invasion of privacy claims, the exclusion
applied because TCPA claims are “implicit”
invasion of privacy claims. A divided panel ofthe Ninth Circuit affirmed.

procedural errors in the arbitration process,and does not extend to the sufficiency of themonetary award. Because there was no claimthat the panel committed any procedural
errors, the trial court’s decision to vacate
based on its disagreement with the panel’s
loss valuation was erroneous.
The Connecticut Supreme Court also founderror in the trial court’s second basis forvacating. Section 52-418(a)(4) provides
that an award should be vacated if thearbitrators have “exceeded their powers or
so imperfectly executed them that a mutual,
final and definite award upon the subject
matter submitted was not made.” The trial
court had applied this provision based on
its finding that the panel disregarded theinsurance policy’s depreciation clause. The
Connecticut Supreme Court ruled, however,that interpretation of policy provisions is atask for the panel, not the court, and that inany event, the trial court misapplied state law
in interpreting the depreciation provision.

TCPA Alert:

Ninth Circuit Rules That “Right To
Privacy” Exclusion Relieves Insurer
Of Duty To Defend TCPA Suit
The Ninth Circuit ruled that an insurer is not
obligated to defend a Telephone Consumer
Protection Act (“TCPA”) suit against the Los
Angeles Lakers based on a policy exclusion
barring coverage for “right to privacy” claims.
Los Angeles Lakers, Inc. v. Federal Ins. Co.,2017 WL 3613340 (9th Cir. Aug. 23, 2017).
The underlying suit alleged that the Lakers
violated the TCPA by sending automated text
message responses to fans who had sent texts

Although the exclusion does not reference
TCPA claims, the court ruled that TCPA
claims fall within its scope as a matterof law. The court held that “invasion ofprivacy” encompasses intrusions upon one’s
seclusion or solitude and is not limited
to invasions based on private content. In
addition, relying on the legislative intent of
the statute, the court concluded that a TCPA
claim is inherently and solely an invasion ofprivacy claim. The court rejected the dissent’s
argument that common law privacy claims(which the underlying plaintiff expressly
waived) are distinct from statutory TCPA
claims and thus that the privacy exclusion
does not necessarily bar coverage forthe latter, which address more than justprivacy concerns (e.g., economic injury,
public safety).

Pollution
Exclusion Alerts:

Fifth Circuit Rules That Pollution
Exclusion Encompasses Asbestos
ClaimsAddressing a matter of first impression
under Texas law, the Fifth Circuit ruled thatasbestos is a “pollutant” within the meaningof a pollution exclusion. Longhorn Gasket& Supply Co. v. United States Fire Ins. Co.,2017 WL 3588304 (5th Cir. Aug. 18, 2017).
Longhorn, a manufacturer of asbestoscontaining products, sued U.S. Fire Insurance
Company, alleging breach of contract for
failure to provide coverage. A Texas district
court ruled that U.S. Fire was obligatedto contribute to underlying defense andsettlement costs. On appeal, U.S. Fire
contested several district court rulings,
6including its finding that the pollution
exclusion was inapplicable. The Fifth
Circuit reversed.
The Fifth Circuit concluded that asbestos is a“pollutant” and “irritant” within the meaningof the exclusion based on its harmful effects
on the body and atmosphere. As the court
noted, other jurisdictions have issued mixed
decisions in this context. The court remanded
the matter for a determination of whether
the “sudden and accidental” exception to the
exclusion applies.

The court held that New Jersey law limits
the application of pollution exclusions to
traditional environmental pollution claims.
Here, because the claims arose out of smallscale and relatively contained contamination,
the court held that the exclusion might not
apply. Additionally, the court reasoned that
under New Jersey law, the pollution exclusion
includes an intent requirement as a matterof public policy. The court concluded thatsummary judgment was inappropriate where,
as here, there were no allegations or evidence
that the homeowners intended to pollutethe property.

Punitive
Damages Alert:

Texas Appellate Court Rules That
Automobile Policy Does Not CoverPunitive Damages

Pollution Exclusion May Not Bar
Coverage For Claims Arising From
Oil Leak, Says New Jersey Court
A New Jersey federal district court denied aninsurer’s summary judgment motion, findingthat a pollution exclusion does not necessarily
bar coverage for contamination claims
stemming from an oil leak. Benjamin v. State
Farm Ins. Co., 2017 WL 3535023 (D.N.J. Aug.
17, 2017).
Homeowners sought coverage for costs
incurred in remediating contamination
caused by a leak in an underground oil tank.
The insurer denied coverage on several
bases, including a pollution exclusionthat bars coverage for loss caused by thedischarge or escape of irritants, pollutants orcontaminants, unless the loss was “sudden
and accidental.” In ensuing litigation, thecourt denied the insurer’s summary judgment
motion, finding that issues of fact exist
as to whether the exclusion applies to thehomeowners’ claims.

Distinguishing prior case law, a Texas
appellate court ruled that an automobile
policy does not provide coverage for punitive
damages. Farmers Texas Cnty. Mutual Ins.
Co. v. Zuniga, 2017 WL 4014644 (Tex. Ct.
App. Sept. 13, 2017).
In a coverage dispute arising out of an
automobile accident, a Texas trial court
ruled that a policy that covers “damages forbodily injury” requires the insurer to pay
for punitive damages. The appellate court
reversed. The appellate court distinguishedcases involving policies that provide coveragefor “all sums which the insured shall become
legally obligated to pay as damages becauseof . . . bodily injury,” explaining that suchlanguage provides broader coverage thanthe language at issue. Although at least one
Texas appellate court has ruled that punitive
damages are covered even in the absenceof “all sums” language, the Farmers court
deemed that ruling “dubious.” In further
support of its decision, the court emphasized
the distinction between compensatory
damages (which address costs associated withbodily injury) and punitive damages (which
address public policy concerns).

7

argued that the underlying action
Contribution Alert: Lloyds
was not a single environmental claim, but

Oregon Appellate Court Rules That
Contribution Claims Are Barred By
State Statute

The Court of Appeals of Oregon ruled thatstate statutory law precludes contribution
claims between insurers for payments madein connection with underlying environmental
claims. Certain Underwriters at Lloyd’s
London v. Mass. Bonding & Ins. Co., 287 Or.
App. 279 (Or. App. Aug. 16, 2017).
Under 2013 amendments to the Oregon
Environmental Cleanup Assistance Act, acontribution action is precluded unless theunderlying environmental claims for which
the insurer seeks contribution had become
subject to “final judgment, after exhaustionof all appeals,” prior to the effective date of
the amendments. Or. Laws 2013, ch. 350§ 8(1)-(2). In the present case, the central
issue in dispute was whether the underlying
claims for which Lloyds sought contribution
had become subject to final judgment prior to
the effective date. An Oregon trial court ruledthat final judgment had not been entered
before the effective date and thus that Lloyd’s
contribution rights were extinguished. The
appellate court affirmed.

rather two separate claims: one for defense
and one for indemnity. Lloyds reasoned that
because it did not appeal the underlying
defense cost ruling (and only appealed
the indemnity findings), there was a “final
judgment” on the defense cost issue prior to
the 2013 amendments. The court rejected thiscontention, explaining that:in determining whether there has beena final judgment after exhaustion of all
appeals, it is not appropriate to examine
the arguments raised on appeal todetermine whether particular issues orclaims were raised before the appellate
court . . . . ‘as long as an appeal ispending, finality does not attach
piecemeal to the parts of a judgment
or order that are not placed in directcontroversy by the parties’ assignments
or arguments in the appeal; it attaches
to the case as a whole after the appellate
process is complete.’
Because an appeal from the environmental
action judgment was pending when the 2013
amendments became effective, the court
concluded that there was no final judgment
and Lloyd’s contribution claim is precluded.

8

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more than a quarter of a century. Our insurance litigation team practices worldwide.

David J. Woll
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scraig@stblaw.com

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

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