Insurance Law Alert

June 2018

In This Issue
California Supreme Court Rules That Insurer Must Defend Negligent
Hiring Claim Arising Out Of Employee’s Intentional Acts
The California Supreme Court ruled that an insurer must defend a suit alleging negligent hiringand supervision of an employee who intentionally injured a third party, finding that suchclaims allege an “occurrence” under a general liability policy. Liberty Surplus Ins. Corp. v.
Ledesma & Meyer Construction Co., Inc., 418 P.3d 400 (Cal. 2018). (Click here for full article)“Overall they
are excellent.
Their work is timely,
well thought out andstrategic.”– Chambers USA 2018(quoting a client)

Finding “Arising Out Of” Ambiguous, First Circuit Rules That Insurer
Must Defend Cosby Defamation Suit
The First Circuit ruled that that an insurer was obligated to defend defamation claims related
to sexual misconduct allegations because a sexual misconduct exclusion was ambiguous. AIG
Prop. Cas. Co. v. Cosby, 2018 WL 2730762 (1st Cir. June 7, 2018). (Click here for full article)

Defending Insurer May Sue Insured’s Appointed Counsel For Malpractice,
Says South Carolina Supreme Court
Answering a certified question, the South Carolina Supreme Court ruled that an insurer may
bring a direct malpractice action against counsel hired to represent its insured. Sentry SelectIns. Co. v. Maybank Law Firm, LLC, 2018 WL 2423694 (S.C. May 30, 2018). (Click here forfull article)

Arizona Appellate Court Rules That Injuries Caused By Several
Independent Acts Are A Single Occurrence
An Arizona appellate court ruled that under applicable policy language an accident caused byseveral independent acts is a single occurrence. Cincinnati Indem. Co. v. Southwestern Line
Constructors Joint Apprenticeship & Training Program, 2018 WL 2440627 (Ariz. App. May
31, 2018). (Click here for full article)

Louisiana Appellate Court Rules That Multiple-Impact Collision Was A
Single Occurrence
A Louisiana appellate court ruled that a multiple-impact collision that injured several
individuals was a single occurrence for insurance coverage purposes. Lloyd’s Syndicate 1861 v.
Darwin National Assurance Co., 2018 WL 2327719 (La. Ct. App. May 23, 2018). (Click here forfull article)
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Ninth Circuit Enforces “Professional Services” Exclusion With Respect To
Qui Tam Claim
The Ninth Circuit ruled that a professional services exclusion in a directors and officers liability
policy bars coverage for a qui tam action against an insured company. HotChalk, Inc. v.
Scottsdale Ins. Co., 2018 WL 2473474 (9th Cir. June 4, 2018). (Click here for full article)

Director Acting In Multiple Capacities Not Entitled To D&O Coverage, Says
North Dakota Court
A North Dakota federal district court ruled that a director is not entitled to coverage under adirectors and officers policy because he was not alleged to have acted solely in his capacity as
a director. Security National Ins. Co. v. H.O.M.E., Inc., 2018 WL 2325406 (D.N.D. May 18,2018). (Click here for full article)

Second Circuit Reverses District Court’s Vacatur Of Reinsurance
Arbitration Award Based On Arbitrator Partiality
The Second Circuit ruled that a New York district court applied an incorrect standard forevaluating the partiality of a party-appointed arbitrator. Certain Underwriting Membersof Lloyds of London v. State of Florida, Dep’t of Fin. Svs., as Receiver for Ins. Co. of theAmericas, 2018 WL 2727492 (2d Cir. June 7, 2018). (Click here for full article)

Massachusetts Court Rules That Unfair Practices Claim Accrues At Last
Settlement Activity, Not Adverse Judgment
A Massachusetts federal district court ruled that a statutory claim against an insurer for unfair
and deceptive business practices accrues no later than the date of the last alleged settlement
misconduct. Hong v. Northland Ins. Co., 2018 WL 2435196 (D. Mass. May 30, 2018).
(Click here for full article)

Colorado Supreme Court Finds That Claim For Unreasonable Benefits
Delay Or Denial Is Not Subject To One-Year Limitations Period
The Colorado Supreme Court ruled that a statutory claim for the unreasonable delay or denialof insurance benefits is not subject to the one-year statute of limitations applicable to actions
brought under any penal statute. Rooftop Restoration, Inc. v. American Family Mutual Ins.
Co., 2018 WL 2407591 (Colo. May 29, 2018). (Click here for full article)

Simpson Thacher News Alerts
Click here for news relating to Simpson Thacher’s insurance-related honors and speaking
engagements.

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Coverage Alert:

California Supreme Court Rules
That Insurer Must Defend Negligent
Hiring Claim Arising Out Of
Employee’s Intentional Acts
The California Supreme Court ruled that aninsurer must defend a suit alleging negligent
hiring and supervision of an employee who
intentionally injured a third party, findingthat such claims allege an “occurrence” undera general liability policy. Liberty Surplus Ins.
Corp. v. Ledesma & Meyer Construction Co.,
Inc., 418 P.3d 400 (Cal. 2018).
A construction company (“L&M”) was hired
to manage a school building project. A
student sued L&M, alleging sexual abuse by aproject supervisor. L&M’s insurers defended
the negligent hiring and supervision claims
under a reservation of rights and soughta declaration of no coverage. A California
federal district court granted the insurers’
summary judgment motion, finding thatthe alleged injury was not caused by an“occurrence” because the injury-causing event
was intentional molestation. The district
court reasoned that L&M’s alleged negligent
hiring and supervision were “too attenuated”
from the injury to establish causation. L&M
appealed, and the Ninth Circuit sought the
California Supreme Court’s guidance.

The California Supreme Court ruled thatthe insurers were obligated to defend thesuit because a potential for coverage exists,
notwithstanding the employee’s alleged
intentional acts. The court rejected the
district court’s causation analysis, holdingthat under California law, causation isestablished so long as the defendant’s conduct
is a “substantial factor” in causing injury.
Applying this framework, the California
Supreme Court reasoned that “a finder of fact

could conclude that the causal connection
between L&M’s alleged negligence and the
injury inflicted . . . was close enough tojustify the imposition of liability on L&M.”
Additionally, the court noted that in deciding
whether underlying claims allege an accident
under an insurance policy, the relevant
viewpoint is that of the insured; thus, thesupervisor’s intentional conduct may bedeemed an unexpected consequence of L&M’s
independent act of negligent hiring.
As discussed in last month’s Alert, theWisconsin Supreme Court recently ruled thata liability policy does not cover negligent
supervision claims that are based solely on an
employee’s intentional conduct.

Defense Alerts:

Finding “Arising Out Of”
Ambiguous, First Circuit Rules
That Insurer Must Defend Cosby
Defamation Suit
Our November 2016 Alert reported ona Massachusetts federal district court’s
holding that that an insurer was obligated todefend defamation claims related to sexual
misconduct allegations because a sexual
misconduct exclusion was ambiguous. AIG
Prop. Cas. Co. v. Green, 2016 WL 6637694(D. Mass. Nov. 8, 2016). This month, the First
Circuit affirmed. AIG Prop. Cas. Co. v. Cosby,
2018 WL 2730762 (1st Cir. June 7, 2018).
The coverage dispute arose out of several
lawsuits against Bill Cosby alleging
defamation and intentional infliction ofemotional distress. The plaintiffs claimed
that Cosby made public statements thatinjured their reputations in response to
their allegations of assault and rape. AIG
sought a declaration that it had no duty to
defend or indemnify the suits, arguing thatthe claims fell within a sexual misconductexclusion, which bars coverage for personal
injury “arising out of any actual, alleged,or threatened . . . sexual molestation,
misconduct, or harassment.” The court
disagreed and denied AIG’s summary
judgment motion and granted Cosby’s motion
in part.
Although Massachusetts law has not clearly
defined the scope of the phrase “arising out
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of,” the First Circuit held that it indicatesa wider range of causation than proximate
causation, but requires a “sufficiently close
relationship” between the injury and relevant
event. Here, AIG argued that the defamation
claims were “inextricably intertwined” withthe excluded sexual assault allegations so as
to trigger the sexual misconduct exclusion.
In contrast, Cosby maintained that the causal
link between the excluded conduct and thedefamation claims was too attenuated to
implicate the exclusion.
Noting that there was no “easy answer” tothe question, the court concluded that theexclusion was ambiguous in light of the policy
as a whole. In particular, the court reasoned
that another, more broadly-worded sexual
misconduct exclusion (relating to Board
Directors and Trustees) mitigated in favorof finding ambiguity because that exclusion
contained more expansive exclusionary
language (e.g., “arising out of or in any way
involving, directly or indirectly, any alleged
sexual misconduct”). The court emphasizedthat “arising out of” is not inherently
ambiguous under Massachusetts law. It
also cautioned that its holding “is confinedto this case where the ambiguity question
is close to begin with and where anothersexual-misconduct exclusion is worded
more broadly.”

insurer. The court explained that although
counsel owes a fiduciary duty only to theinsured, the “unique position” of the insurer
in this context mitigates in favor of allowing
a malpractice claim. In so ruling, the courtemphasized that appointed counsel owes noseparate duty to the insurer and that South
Carolina does not recognize a “dual attorneyclient relationship.”
The court limited its holding in several
important respects. First, an insurer may
recover for counsel’s breach of his duty
only where the insurer proves by clear
and convincing evidence that the breachproximately caused damage to the insurer.
Second, there can be no liability if theinterests of the client “are the slightest bitinconsistent with the insurer’s interests.”
Potential inconsistencies are to be evaluatedon a case-by-case basis.
As the court noted, the majority of states thathave considered this issue have similarly
allowed an insurer to pursue a malpracticeclaim against appointed counsel.

Number Of
Occurrence Alerts:

Defending Insurer May Sue
Insured’s Appointed Counsel For
Malpractice, Says South Carolina
Supreme Court

Arizona Appellate Court Rules
That Injuries Caused By Several
Independent Acts Are A Single
Occurrence

Answering a certified question, the South
Carolina Supreme Court ruled that an insurer
may bring a direct malpractice action against
counsel hired to represent its insured. Sentry
Select Ins. Co. v. Maybank Law Firm, LLC,
2018 WL 2423694 (S.C. May 30, 2018).

An Arizona appellate court ruled that underapplicable policy language an accident
caused by several independent acts is asingle occurrence. Cincinnati Indem. Co.
v. Southwestern Line Constructors Joint
Apprenticeship & Training Program, 2018
WL 2440627 (Ariz. App. May 31, 2018).

An insurer hired attorney Roy Maybank to
defend its insured in a personal injury suit.
When Maybank failed to timely answer
requests to admit, the insurer settled thesuit for an amount larger than originally
anticipated based on the likelihood of an
adverse ruling. It then sued Maybank alleging
malpractice.
The South Carolina Supreme Court ruled thatthe insurer’s malpractice action was viable,
notwithstanding the absence of an attorneyclient relationship between counsel and theTwo workers were injured when a utility
pole broke while they were working on it.
They sued the construction company andultimately reached a settlement for the limitsof the company’s liability policy. The policy
contained a $1 million per-occurrence limit
and a $2 million aggregate limit. The insurersought a declaration that the employees’
injuries arose from a single occurrence andits obligation was therefore capped by the $1
million limit. An Arizona trial court agreed,
and the appellate court affirmed.
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The policy defined “occurrence” as “anaccident, including continuous or repeatedexposure to substantially the same general
harmful conditions.” The appellate court
ruled that there was only one occurrence
because the injuries resulted from a single
accident (i.e., the collapse of the utility pole).
The employees argued that under Arizonalaw, the number of occurrences is determinedby the number of allegedly negligent acts,
and that here, at least five separate acts ofnegligence caused the pole to break, including
the use of wooden poles, the failure to
perform inspections and the lack of secondary
support or supervision. The court rejected
this assertion, explaining that a “negligentact” analysis is appropriate only where policy
language defines “occurrence” in relation
to incidents, acts or omissions that result ininjury. Where, as here, occurrence is defined
as an “accident” (rather than the precipitating
cause of the accident), the number ofantecedent negligent acts is irrelevant.

Louisiana Appellate Court Rules
That Multiple-Impact Collision Was
A Single Occurrence
A Louisiana appellate court ruled thata multiple-impact collision that injured
several individuals was a single occurrence
for insurance coverage purposes. Lloyd’s
Syndicate 1861 v. Darwin National
Assurance Co., 2018 WL 2327719 (La. Ct.
App. May 23, 2018).
The coverage dispute arose out of an
automobile accident that spanned a nearly
one mile distance from initial to final impact.
During the course of the incident, the insured
driver struck four different vehicles at ahigh rate of speed, resulting in numerous
injuries. The parties disputed whether theincident constituted one occurrence or
multiple occurrences under Louisiana law.
A trial court ruled that the accident was asingle occurrence, subject to a single policy
limit under the driver’s policy. The appellate
court affirmed.
Addressing this matter of first impression
under Louisiana law, the appellate court
applied a causation test under which “aninsured tortfeasor will be limited to a single
policy limit for a single accident in situations
where all of the successive impacts are
the result of the same cause as the initial
impact” unless there are “new and distinct,

intervening cause[s].” The court expressly
rejected a “time and space” test under which
accidents separated by time and space areconsidered multiple occurrences. However,the court noted that factors relating to timeand space are not irrelevant to the causation
test; rather, a court may consider a time lapse
or spatial range in evaluating whether injuries
are the result of a single occurance or multiple
occurrences. Applying this framework to
the factual record, the court concluded thatthe successive collisions were the result of asingle cause without any intervening acts ofnegligence between impacts.

Professional
Services Alert:

Ninth Circuit Enforces“Professional Services” Exclusion
With Respect To Qui Tam Claim
The Ninth Circuit ruled that a professional
services exclusion in a directors and officers
liability policy bars coverage for a qui tam
action against an insured company. HotChalk,
Inc. v. Scottsdale Ins. Co., 2018 WL 2473474(9th Cir. June 4, 2018).
HotChalk, a company that provides online
marketing and technology services touniversities, was sued by former employees
in a qui tam action. The suit alleged that
HotChalk violated federal regulations
concerning the enrollment of students who
received federal financial aid, causing boththe students and universities with which
HotChalk partnered to submit false claims
to the government. Scottsdale Insurance
denied coverage and refused to defend thesuit based on the policy’s professional services
exclusion. In ensuing litigation, a California
district court granted Scottsdale’s summary5

judgment motion. The Ninth Circuit affirmed,
ruling that the allegations in the qui tam suitagainst HotChalk “arose out of” the renderingof professional services because they involved
HotChalk’s professional services of recruiting
students and providing support services to theuniversities.

D&O Alert:

Director Acting In Multiple
Capacities Not Entitled To D&O
Coverage, Says North Dakota Court
Addressing a matter of first impression underNorth Dakota law, a North Dakota federal
district court ruled that a director is notentitled to coverage under a directors andofficers policy because he was not alleged tohave acted solely in his capacity as a director.
Security National Ins. Co. v. H.O.M.E., Inc.,2018 WL 2325406 (D.N.D. May 18, 2018).

The court rejected Molbert’s assertion thathe acted solely in his capacity as director
with respect to at least some claims (i.e., thestatutory claims that apply only to directors
and officers), finding that the counterclaims“not only allege[] he simultaneously acted
in noncovered capacities during all relevanttimes but also that these capacities aided
the breach of his fiduciary duties as director
and officer.”
Alternatively, the court ruled that even if
there was ambiguity with respect to coverage
under the policy, the counterclaims would
nonetheless be excluded under the insured
vs. insured exclusion because the siblings
were “insureds” under the policy. The
court rejected H.O.M.E.’s contention thatthe exclusion ought not apply because theunderlying litigation did not raise concerns
about collusion among insureds.

Arbitration Alert:
Second Circuit Reverses District
Court’s Vacatur Of Reinsurance
Arbitration Award Based On
Arbitrator Partiality

Lauris Molbert, president and CEO of
H.O.M.E., sued his siblings in connection
with a stock purchase agreement. The
siblings alleged several counterclaims against
Molbert, including breach of fiduciary duty
and violation of state statutory law. Security
National, H.O.M.E.’s D&O insurer, denied
coverage for the counterclaims. In ensuingcoverage litigation, the court granted Security
National’s summary judgment motion,
finding no coverage under the policy.

Our April 2017 Alert reported on a New Yorkfederal district court decision vacating an
arbitration award in a reinsurance dispute
based on an arbitrator’s failure to disclose
his relationship with a party to the dispute.
Certain Underwriting Members at Lloyd’sof London v. Insurance Co. of the Americas,
2017 WL 5508781 (S.D.N.Y. Mar. 31, 2017).
This month, the Second Circuit vacatedthe decision, finding that the district court
applied an incorrect standard for evaluating
the partiality of a party-appointed arbitrator.
Certain Underwriting Members of Lloyds of
London v. State of Florida, Dep’t of Fin. Svs.,
as Receiver for Ins. Co. of the Americas, 2018
WL 2727492 (2d Cir. June 7, 2018).

The court ruled that the siblings’
counterclaims were not covered because
the allegations did not assert that Molbert
was acting “solely in [his] capacity as
director” as required by the policy. The court
reasoned that the counterclaims “inextricablyintertwine” Molbert’s role as lawyer with hisrole as director because they allege that his
legal work directly facilitated the breach of
duties that he owed the company as director.

ICA entered into reinsurance treaties withcertain Lloyd’s Underwriters. When adispute over a reinsurance claim arose, ICA
demanded arbitration and designated Alex
Campos as its arbitrator. Each arbitration
panel member made affirmative disclosures
regarding their relationships with theparties and individuals involved in thedispute. Campos indicated that he had no
personal relationship with any party or any
6business relationship with ICA. At the endof arbitration, the panel issued an award
in ICA’s favor. The Underwriters moved tovacate the award based on Campos’ evident
partiality. The district court granted the
motion, concluding that the Underwriters
had established evident partiality by clear
and convincing evidence based on Campos’
failure to disclose his extensive business
relationships with ICA and individuals
associated with ICA.
The Second Circuit disagreed, holding that a
party seeking to vacate an award under theFederal Arbitration Act must sustain a highburden to prove evident partiality on the partof a party-appointed arbitrator. Noting thatparty-appointed arbitrators are “expected
to espouse the view or perspective of theappointing party,” the court held that evident
partiality in this context requires a heightened
showing that the relationship violates thecontractual requirement of disinterestedness,or it prejudicially affects the award. As thecourt noted, several other circuit courts haveconcluded that the disclosure requirements
for neutral arbitrators/umpires do not extend
to party-appointed arbitrators.
The Second Circuit remanded the matterfor a determination as to whether theUnderwriters have shown by clear andconvincing evidence that Campos’ omissions
violated the contractual requirement of“disinterestedness” or had a prejudicial
impact on the award.

Statute Of
Limitations Alerts:
Massachusetts Court Rules That
Unfair Practices Claim Accrues
At Last Settlement Activity, Not
Adverse Judgment

A Massachusetts federal district court ruledthat a statutory claim against an insurer
for unfair and deceptive business practices
accrues no later than the date of the last
alleged settlement misconduct. Hong v.
Northland Ins. Co., 2018 WL 2435196 (D.
Mass. May 30, 2018).
In November 2017, Hong sued his insurer
for unfair and deceptive practices under

Massachusetts statutory law (Mass. Gen.
Laws ch. 93A, § 9). The complaint alleged thatin September 2013, the insurer withdrew a$4,000 settlement offer and that in November
2013, a trial verdict was entered against theinsurer in the amount of nearly $60,000. The
insurer argued that the statutory claim wastime-barred under the applicable four-year
statute of limitations. The court agreed.

The court held that the claim accrued nolater than September 2013, the last dateof settlement activity. The court stated:“The injury alleged here is the failure tooffer a reasonable settlement under thecircumstances. This was fully known as of
September 24, 2013 when the defendant
insurer rescinded its $4,000 offer.” The court
rejected Hong’s assertion that the claim did
not accrue until the adverse judgment wasentered against the insurer, noting that thestatute of limitations begins when actionableinjury or harm occurs, which in this case, wasthe rescinding of the settlement offer.

Colorado Supreme Court Finds
That Claim For Unreasonable
Benefits Delay Or Denial Is Not
Subject To One-Year Limitations
PeriodAnswering a certified question, the Colorado
Supreme Court ruled that a statutory claim forthe unreasonable delay or denial of insurance
benefits is not subject to the one-year statuteof limitations applicable to actions brought
under any penal statute. Rooftop Restoration,
Inc. v. American Family Mutual Ins. Co.,2018 WL 2407591 (Colo. May 29, 2018).
A contractor, as assignee of benefits under ahomeowners’ policy, alleged several causesof action against an insurer, including astatutory claim based on the unreasonable
delay or denial of policy benefits. See Section
7

Simpson Thacher
News Alerts

10-3-1116, C.R.S. (2017). The insurer argued
that the claim was time-barred under the oneyear statute of limitations set forth in section
13-80-103(1)(d), C.R.S. (2017), which applies
to “all actions for any penalty or forfeitureof any penal statutes.” The court disagreed,finding that the denial of insurance benefits
statute was not “penal” under Colorado law.
The court declined to apply the three-part test
previously adopted by the Colorado Supreme
Court in evaluating the “penal” nature ofa statute. See Kruse v. McKenna, 178 P.3d
1198 (Colo. 2008). The court stated that “ifthe legislature even implicitly indicates thata statute is not penal for the purposes ofidentifying the correct statute of limitations,then our judicially created test must yield
to the intent of the legislature.” The court
inferred that the legislature did not intend
to make section 10-3-1116 penal based on an
accrual statute, 13-80-108, which provides
that a cause of action for penalties accrues“when the determination of overpayment
or delinquency for which such penalties areassessed is no longer subject to appeal.”
The court did not specify the applicablestatute of limitations and remanded thematter for further proceedings.

Simpson Thacher has been honored by the
New York Law Journal as its 2018 Litigation
Department of the Year in the category of
Insurance. The publication selected Simpson
Thacher based on client feedback, impressive
victories and involvement in important
insurance and reinsurance-related litigation.
Legal 500 has ranked Simpson Thacher as
a leading law firm in the United States. The
Firm was recognized in 44 practice areas,
including in the field of Insurance: Advice
to Insurers.
Mary Beth Forshaw was named “Bestin Insurance and Reinsurance” at theEuromoney Legal Media Group Americas
Women in Business Law Awards 2018.
Deborah Stein recently spoke at thePractising Law Institute’s “Insurance
Coverage Litigation – Insurer andPolicyholder Perspectives” webinar about
litigation strategies and best practices ininsurance matters.
Elisa Alcabes spoke at the New York State Bar
Association’s Insurance Coverage Update: A
Glimpse Forward and A Glance Back CLE lastmonth in New York City. Elisa participated ona panel titled “Excess Coverage: Umbrella v.
Follow-Form, Obligations between Primaryand Excess; Reporting to Excess; Claims in
Excess of Limits; and Burning Limits,” which
discussed excess and umbrella insurance
coverage issues and recent noteworthy
decisions.

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

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

Elisa Alcabes+1-212-455-3133
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

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
or matters, nor does the distribution of this publication to any person constitute the establishment of an
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Please click here to subscribe to the Insurance Law Alert.
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