Insurance Law Alert

March 2017

In This Issue
Texas Supreme Court Rejects Narrow Construction Of Insured vs. Insured
Exclusion
The Supreme Court of Texas ruled that an insured vs. insured exclusion bars coverage forclaims asserted against a former director by an insurance company standing in the shoes of theinsured company. Great American Ins. Co. v. Primo, 2017 WL 749870 (Tex. Feb. 24, 2017).
(Click here for full article)“SimpsonThacher has many
litigators who are very
experienced in handlingcomplex, multi-faceted
litigation involving
novel issues.”–Benchmark 2017,
quoting a client

Ninth Circuit Rejects Coverage Under Computer Fraud Provision For
Fraudulent Wire Transfer Claims
The Ninth Circuit ruled that an insurer does not owe coverage under a computer fraud
provision for losses arising out of wire transfers that occurred as a result of fraudulent emails.
Taylor & Lieberman v. Fed. Ins. Corp., 2017 WL 929211 (9th Cir. Mar. 9, 2017). (Click here forfull article)

Georgia Court Rules That Computer Fraud Provision Does Not Encompass
Fraudulent Debit Card Transactions
A Georgia federal district court ruled that losses caused by fraudulent debit card transactions
are not covered by a computer fraud provision. InComm Holdings, Inc. v. Great Am. Ins. Co.,2017 WL 1021749 (N.D. Ga. Mar. 16, 2017). (Click here for full article)

Insurer May Depreciate Labor Costs In Calculating Actual Cash Value,
Rules Nebraska Supreme Court
The Nebraska Supreme Court ruled that where a policy is silent on the issue, an insurer may
consider the depreciation of labor costs in determining the actual cash value of a covered loss.
Henn v. American Family Mutual Ins. Co., 295 Neb. 859 (Neb. Feb. 17, 2017). (Click here forfull article)

Insurer Not Bound By Consent Judgment Executed By Underlying Parties,
Says West Virginia Supreme Court
The West Virginia Supreme Court ruled that an insurer is not bound by a consent judgment
executed by opposing parties in an underlying suit in conjunction with a covenant not to
execute and an assignment of claims against the insurer. Penn-America Ins. Co. v. Beecher,2017 WL 878716 (W. Va. Mar. 1, 2017). (Click here for full article)
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Simpson Thacher & Bartlett LLP

1

Oregon Court Rules That Pollution Exclusion Bars Coverage For Carbon
Monoxide Claims
Ruling on a matter of first impression under Oregon law, an Oregon federal district court ruledthat a pollution exclusion unambiguously bars coverage for claims alleging injury caused bycarbon monoxide. Colony Ins. Co. v. Victory Constr. LLC, 2017 WL 960024 (D. Or. Mar. 9,2017). (Click here for full article)

Connecticut Appellate Court Addresses Allocation Issues In AsbestosInjury Context
A Connecticut appellate court addressed the proper allocation of defense and indemnity forlong-term asbestos-related injury claims, resolving several matters of first impression under
Connecticut law. R.T. Vanderbilt Co., Inc. v. Hartford Accident and Indem. Co., 2017 WL
810704 (Conn. App. Ct. Mar. 7, 2017). (Click here for full article)

Applying Cause-Based Approach, Ohio Court Rules That Sale of Defective
Products Constitutes Multiple Occurrences
An Ohio federal district court ruled that injuries allegedly caused by defective torches and/or
improper fuel arose out of multiple occurrences, not a single decision to sell those products.
Big Lots Stores, Inc. v. American Guarantee & Liability Ins. Co., No. 2:14-cv-02635 (S.D. Ohio
Mar. 2, 2017). (Click here for full article)

STB News Alerts:
Click here for information relating to recent insurance-related publications by Simpson
Thacher attorneys.

2

D&O Alert:

Texas Supreme Court Rejects
Narrow Construction Of Insured vs.
Insured Exclusion
Reversing an appellate court decision, theSupreme Court of Texas ruled that an insured
vs. insured exclusion bars coverage for claims
asserted against a former director by aninsurance company standing in the shoes of
the insured company. Great American Ins.
Co. v. Primo, 2017 WL 749870 (Tex. Feb.
24, 2017).

The Texas Supreme Court ruled that theappellate court erred in applying a corporatebased “successor” analysis given the absenceof that term in the exclusion. As the Texas
Supreme Court emphasized, the exclusion
does not use the term “successor” or“successor-in-interest.” Rather, it requiresthat the party bringing suit “succeed” to theinterests of Briar Green. Further, the Texas
Supreme Court reasoned that applying
the plain meaning of “succeeds” (falls heir
to, inherits or comes into possession of)comports with the purpose of the exclusion– to prevent collusive suits between
organizations and their officers.

Computer Fraud
Coverage Alerts:

Ninth Circuit Rejects Coverage
Under Computer Fraud Provision
For Fraudulent Wire Transfer
ClaimsRobert Primo served as a director of Briar
Green, a non-profit organization. After
Primo resigned, Briar Green allegedly
discovered that he had misappropriatedfunds and sought coverage for those losses
from Travelers, its fidelity insurer. Travelers
paid the claim in exchange for a written
assignment of Briar Green’s rights andclaims against Primo. Travelers, standing inthe shoes of Briar Green, then sued Primo
to recover the funds. Thereafter, Primosued Great American, Briar Green’s D&O
insurer, seeking reimbursement of the costs
he incurred in the Travelers suit. Great
American argued that coverage was barredby the insured vs. insured exclusion, whichapplies to claims against an insured made by
Briar Green “or … any person or entity which
succeeds to the interests of [Briar Green].”A Texas trial court agreed that the exclusion
applied. An intermediate appellate court
reversed, reasoning that the exclusion did
not apply because Travelers was not Briar
Green’s “successor.” The appellate court heldthat Texas common law requires a “successor”
to acquire the rights of another entity and“maintain[ ] the character of the place taken.”
The Texas Supreme Court reversed.

As discussed in previous Alerts, courts
have rejected policyholder attempts toobtain coverage for cyber-related losses
under computer fraud and other similar
policy provisions. In Apache Corp. v. Great
American Ins. Co., 2016 WL 6090901 (5thCir. Oct. 18, 2016), the Fifth Circuit ruled thata computer fraud provision does not coverclaims arising out of the transfer of funds tocriminal accounts because a fraudulent email
was only one part of a chain of events thatcaused the loss, and the loss therefore was
not caused “directly” by computer use. See
November 2016 Alert. Similarly, in Universal
Am. Corp. v. Nat’l Union Fire Ins. Co. of
Pittsburgh, PA, 2015 WL 3885816 (N.Y. June25, 2015), the New York Court of Appeals
ruled that coverage for the “fraudulent
entry” of data is limited to losses caused byunauthorized access into the policyholder’scomputer system and does not encompass
losses caused by an authorized user’s
submission of fraudulent information into thecomputer system. See July/August 2015 Alert.
This month, the Ninth Circuit, applying
similar reasoning, ruled that an insurer
does not owe coverage for losses arising outof wire transfers that occurred as a resultof fraudulent emails. Taylor & Lieberman
v. Fed. Ins. Corp., 2017 WL 929211 (9th3Cir. Mar. 9, 2017). The court reasoned thatcoverage was not available under a computer
fraud provision because “sending an email,without more” does not constitute an
unauthorized “entry into” a computer system,
as required by the coverage grant. The court
explained that the emails that instructed
the policyholder to effectuate the wiretransfers do not amount to trespass into a
computer system. The court also held that the
fraudulent emails are not an “introduction of
instructions” that “propogate[d] themselves”
through the computer system, explainingthat those policy terms refer to malicious
computer codes and other similar intrusions.
In addition, the court ruled that there isno coverage under a forgery provision that
protects against loss “resulting from Forgery
or alteration of a Financial Instrument
by a Third Party.” The court rejected thepolicyholder’s contention that under the“last antecedent rule,” the words “financial
instrument” only limit coverage for analteration, and that a forgery need not be ofa financial instrument. Instead, the court
concluded that under a “natural reading of
the policy,” forgery coverage extends only toforgery of a financial instrument (and not toa fraudulent email). Finally, the court ruledthat there is no funds transfer fraud coverage
because that provision requires transfers to
be made “without an Insured Organization’s
knowledge or consent.” Here, the policyholder
knew about the wire transfers and in factdirected the transfer of funds after receiving
the fraudulent emails.

Georgia Court Rules That Computer
Fraud Provision Does Not
Encompass Fraudulent Debit Card
Transactions
A Georgia federal district court ruled thatlosses caused by fraudulent debit cardtransactions are not covered by a computer
fraud provision. InComm Holdings, Inc. v.
Great Am. Ins. Co., 2017 WL 1021749 (N.D.
Ga. Mar. 16, 2017).

(computer servers that process the requested
transactions). A vulnerability in InComm’s
processing center allowed cardholders to
add credit to their debit cards in multiplesof the amount actually purchased. Before
InComm discovered this flaw, unauthorized
redemptions caused InComm to transmit
more than $11 million to various debit card
issuers. InComm sought coverage from Great
American for these losses, which the insurer
denied. In ensuing coverage litigation, thecourt agreed with Great American that thepolicy’s computer fraud provision does notencompass the losses at issue.
The computer fraud provision covers losses“resulting directly from the use of any
computer to fraudulently cause a transfer” ofmoney, securities or other property. The court
found that the underlying transfers were
not caused by “use of a computer” because
they were caused directly by the automatedtelephone system. Although a computer
processing system was also involved in
the transactions, the court deemed thatinvolvement insufficient to constitute useof a computer. The court stated: “A person‘uses’ a computer where he takes, holds or
employs it to accomplish something. That acomputer was somehow involved in a loss
does not establish that the wrongdoer ‘used’
a computer to cause the loss. To hold sowould unreasonably expand the scope of theComputer Fraud Provision.” Additionally,
the court held that even if a computer wasused, the losses did not “result directly” fromcomputer use because they “occurred only
after InComm wired money to [a bank],
after the cardholder used his card to pay fora transaction, and after [the bank] paid theseller for the cardholder’s transaction.” In soruling, the court relied on Apache Corp. v.
Great American Ins. Co., 2016 WL 6090901(5th Cir. Oct. 18, 2016), in which the court,
considering an identical computer fraud
provision, denied coverage for wire transfers
made at the direction of fraudulent emails.

InComm provides a service that allows
customers to load funds onto prepaid
debit cards issued by banks. Cardholders
can purchase “chits” from retailers to add
funds onto the cards. InComm processes
such requests by using an Interactive
Voice Response System (i.e., telephone)
as well as Application Processing Servers
4

Property
Insurance Alert:

Insurer May Depreciate Labor
Costs In Calculating Actual Cash
Value, Rules Nebraska Supreme
Court
As discussed in our January and February
2016 Alerts, courts disagree as to whether
labor costs can be depreciated for the
purposes of calculating actual cash value(“ACV”) under a property policy. The
Arkansas Supreme Court has ruled that state
law prohibits the depreciation of labor costs,
even where the policy expressly allows forsuch depreciation, whereas the Minnesota
Supreme Court has ruled that the questionof depreciation should be left to the trierof fact. Last month, the Nebraska Supreme
Court weighed in, ruling that where a policy
is silent on the issue, an insurer may consider
the depreciation of labor costs in determining
the ACV of a covered loss. Henn v. American
Family Mutual Ins. Co., 295 Neb. 859 (Neb.
Feb. 17, 2017).
Although Nebraska courts have used various
approaches to calculate ACV, the Nebraska
Supreme Court noted that all approaches
are based on the principle that “actual cash
value is the value of the property in its
depreciated condition.” Therefore, the court
concluded that:
The unambiguous definition of actual
cash value is a depreciation of thewhole. As such, the insured is notunderindemnified by receiving thedepreciated amount of both materials
and labor. We agree with American
Family that a payment of actual cash
value that included the full costs oflabor would amount to a prepaymentof unearned benefits.
In so ruling, the court noted that allowing
consideration of depreciated labor costs is
consistent with Nebraska’s “broad evidence
rule,” which allows “all relevant facts andcircumstances to be considered.”

Settlement Alert:

Insurer Not Bound By Consent
Judgment Executed By Underlying
Parties, Says West Virginia
Supreme Court
The West Virginia Supreme Court ruledthat an insurer is not bound by a consent
judgment executed by opposing parties inan underlying suit in conjunction with acovenant not to execute and an assignment ofclaims against the insurer. Penn-America Ins.
Co. v. Beecher, 2017 WL 878716 (W. Va. Mar.
1, 2017).
After sustaining injuries in a timbering
accident, Osborne sued his employer (H&H
Logging) as well as the owner and lessorof the land on which the accident occurred(Heartwood and Allegheny). H&H tendered
the suit to its insurer, Penn-America, which
denied coverage based on a policy exclusion.
Thereafter, H&H retained counsel at its own
expense. Heartwood and Allegheny were
defended by Liberty Mutual, Allegheny’s
insurer. Although Heartwood and Alleghenydiscovered that their timber contract with
H&H required H&H to defend and indemnify
them for job-related accidents, they did
not forward that information to or request
indemnity from Penn-America. Prior to trial,
the parties reached a settlement containing
three components: (1) a consent judgmentin which Heartwood and Allegheny agreed
to a $1 million judgment against them;(2) a covenant not to execute the judgment;and (3) an assignment to Osborne of all
claims Heartwood and Allegheny might
have against Penn-America. Pursuant to thesettlement, Osborne dismissed his claims
against Heartwood and Allegheny and sued
Penn-America. A West Virginia circuit court
granted Osborne’s summary judgment motion
and ordered Penn-America to pay the $1
million consent judgment (which represented
its policy limits). The West Virginia Supreme
Court reversed.
The West Virginia Supreme Court ruled thatthe consent judgment was not binding on
Penn-America because it was not a party
to the settlement or the lawsuit in which
the consent judgment was entered. In soruling, the court noted the lack of factual
support for the $1 million judgment as a“fair and reasonable valuation” of Osborne’s
injuries. The court rejected the argument
5

that Penn-America should nonetheless bebound by that amount because it did notexceed policy limits. Additionally, the court
ruled that the assignment of claims was void
because it was based on false factual bases.
In particular, the assignment was expressly
based on the assertion that Heartwood andAllegheny were without insurance coverageand that the consent judgment was necessary
to protect their assets, when, in fact, they
were provided coverage and a defense by
Liberty Mutual. Finally, the court noted thesymptoms of fraud and collusion in thiscase: an unreasonable judgment amountand concealment of the settlement from
Penn-America.

Pollution Exclusion
Alert:
Oregon Court Rules That Pollution
Exclusion Bars Coverage For
Carbon Monoxide Claims

Ruling on a matter of first impression under
Oregon law, an Oregon federal district
court ruled that a pollution exclusion
unambiguously bars coverage for claims
alleging injury caused by carbon monoxide.
Colony Ins. Co. v. Victory Constr. LLC, 2017
WL 960024 (D. Or. Mar. 9, 2017).
Lawsuits filed against Victory Construction
alleged negligence and failure to warnin connection with the installation of aswimming pool heater. The complaints
alleged that as a result of Victory’s negligence,
excessive carbon monoxide entered a home,causing injury to its residents. Colony
Insurance denied coverage based on apollution exclusion. Ruling on the parties’
cross-motions for summary judgment, thecourt held that the pollution exclusion bars
coverage and that Colony has no duty to
defend or indemnify the claims.
Predicting that the Oregon Supreme Court
would apply a pollution exclusion to preclude
coverage for carbon monoxide claims, thecourt rejected three assertions made byVictory. First, the court held that exclusion
is not limited to traditional environmental
pollution based on the “plain meaning” of
the terms of the exclusion, without resort
to extrinsic evidence. In so ruling, the court

expressly disagreed with the Nevada Supreme
Court’s ruling in Century Surety Co. v.
Casino West, Inc., 329 P.3d 614 (Nev. 2014)(discussed in our June 2014 Alert). Second,the court ruled that Victory’s reasonable
expectations were irrelevant to interpretationof the pollution exclusion, noting that the
Oregon Supreme Court has not expressly
adopted a reasonable expectations doctrine
and that state statutory law (requiring
insurance contracts to be interpreted
according to their terms and conditions)appears to be inconsistent with the doctrine.
Finally, the court concluded that the exclusion
was unambiguous on its face, rejecting
Victory’s assertion of ambiguity based on
conflicting case law.
As discussed in previous Alerts, othercourts have likewise concluded that carbon
monoxide injury claims fall squarely within
the scope of a standard pollution exclusion.
See March 2016 Alert, June 2013 Alert, Sept.
2012 Alert.

Allocation Alert:
Connecticut Appellate Court
Addresses Allocation Issues In
Asbestos-Injury Context

A Connecticut appellate court addressed theproper allocation of defense and indemnity
for long-term asbestos-related injury claims,
resolving several matters of first impression
under Connecticut law. R.T. Vanderbilt
Co., Inc. v. Hartford Accident and Indem.
Co., 2017 WL 810704 (Conn. App. Ct. Mar.
7, 2017).
The coverage dispute arose from thousandsof underlying asbestos-related personal
injury lawsuits against Vanderbilt. In
this interlocutory appeal, Vanderbilt andapproximately thirty insurance companies
sought declarations regarding their respective
obligations as to the underlying claims.
Among other things, the parties challenged
the trial court’s allocation and policy
exclusion rulings. Reversing in part andaffirming in part, the appellate court ruled
as follows:
Trigger: The court rejected Vanderbilt’scontention that Connecticut law has
definitively endorsed a continuous trigger
6

for long-tail asbestos injury claims. Rather,
the court held that trigger remains an“open question” in Connecticut. The court
also rejected Vanderbilt’s assertion thattrigger presents a question of fact that
requires expert testimony. Instead, the court
concluded that trigger must be determined by
the court as a matter of law and that the trial
court properly excluded scientific/medical
testimony in this context. Turning to thesubstantive issue at hand, the court ruledthat a continuous trigger governs asbestosrelated claims, under which “every policy
in effect, beginning at the time of initial
exposure and extending through the latency
period and up to the manifestation of asbestos
related disease, is on the risk for defense andliability costs.”

Unavailability of Insurance: The court
addressed whether Vanderbilt should be
responsible for costs prorated to periods inwhich it was uninsured not by choice, but
because insurance coverage was unavailable.
The insurers argued that Connecticut law
does not recognize an unavailability rule, andthat even if it does, an equitable exception
existed because Vanderbilt “continue[d] toplace allegedly harmful products into thestream of commerce during a time when nocoverage [was] available for losses attributed
to those products.” The court rejected bothcontentions. First, the court endorsed an
unavailability rule under Connecticut law,
but held that the trial court misapplied therule. In particular, the appellate court founderror in the trial court’s reasoning that
occurrence-based insurance was available
from 1993 through 2007 based on the limited
availability of claims-made coverage. The
appellate court also noted a lack of factual
support for the finding that Vanderbilt could

have obtained coverage during this timeframe, but chose not to. Second, the court
declined to rule on whether Connecticut
would adopt an equitable exception to thisrule, instead finding that even if such an
exception existed, the factual record did notsupport its application because Vanderbilt
had a good faith belief that its talc did notcontain asbestos during the relevant period of
no insurance.
Excess and Umbrella Coverage: The court
ruled that an allocation agreement among
primary insurers was enforceable against
umbrella and excess insurers that were notparties to the allocation agreement. The court
noted that while potentially collusive or badfaith agreements may be challenged by excess
insurers, the factual record did not suggest
any such impropriety. The court also ruledthat Continental’s umbrella policies wereunambiguous and that language obligating
Continental to defend “an occurrence notcovered in whole or in part by underlying
insurance” does not create a defense
obligation when primary coverage wasavailable and has been exhausted.
Pollution Exclusion: The court held that astandard pollution exclusion is ambiguous
as to whether it applies only to traditional
environmental contamination or “morebroadly to circumstances such as the releaseof asbestos dust and similar toxic industrial
products within a building when used asintended.” However, the court noted that tothe extent that the factual record establishes
traditional environmental contamination(e.g., the outdoor dumping of silica waste
onto neighboring properties), the exclusion
may apply.
Occupational Disease Exclusions:
Addressing a matter of first impression inConnecticut and nationally, the court ruledthat occupational disease exclusions are notlimited to claims brought by a policyholder’sown employees. Rather, the exclusion
also bars claims brought by complainants
who developed occupational disease while
using the policyholder’s products in thecourse of working for another employer.
The court reasoned that although the term
“occupational disease” may be used inworkers’ compensation law, “it does notfollow that the term applies only to workers’
compensation claims brought against one’s
own employer.”7

Number ofOccurrences Alert:
Applying Cause-Based Approach,Ohio Court Rules That Sale of
Defective Products Constitutes
Multiple Occurrences

An Ohio federal district court ruled thatinjuries allegedly caused by defective torches
and/or improper fuel arose out of multiple
occurrences, not a single decision to sell those
products. Big Lots Stores, Inc. v. American
Guarantee & Liability Ins. Co., No. 2:14-cv02635 (S.D. Ohio Mar. 2, 2017).
The coverage dispute arose out of lawsuits
filed against Big Lots alleging personal
injuries caused by tabletop torches sold in
combination with a particular fuel. Someunderlying complaints alleged that Big Lots
was involved in the design and manufactureof the torches while others alleged only that
Big Lots sold and distributed the torches.
In one case, a Texas court ruled that Big
Lots was a non-manufacturing seller of
the torches. In the present suit, American
Guarantee disputed its coverage obligations
under umbrella policies issued to Big Lots.
More specifically, the parties disagree as
to whether Big Lots’ primary policy has
been exhausted – an issue that depends onwhether the underlying claims allege a single
occurrence or multiple occurrences.
Applying a cause-oriented analysis under
Ohio law, the court concluded that the torch
claims constituted multiple occurrences. The

court reasoned that there was not “but one
proximate, uninterrupted and continuingcause which resulted in all of the injuries,” asrequired by the cause test. The court rejected
Big Lots’ contention that its single “chainof business decisions” led to the underlying
injuries. The court distinguished single
occurrence-product defect cases on the basis
that, in those cases, the policyholder was the
manufacturer (rather than the seller). Here, incontrast, each sale of a torch presented a “newexposure” and a separate “act from which
liability arose.” The court also distinguished“failure to warn” cases, in which courts havefound that numerous injuries arise from asingle occurrence.

STB News Alerts:
Mary Beth Forshaw and Elisa Alcabes
edited Getting the Deal Through: Insurance
Litigation, a publication that provides expert
advice and insight into contentious insurance
issues, and co-authored its chapter on UnitedStates law.
The 18th edition of the Handbook on
Insurance Coverage Disputes has recently
been released. The Handbook, co-authoredby retired Simpson Thacher partner andacting New York State Supreme Court Justice
Barry R. Ostrager, and edited by Elisa Alcabes
and Karen Cestari, discusses thousands of
insurance and reinsurance-related decisions
issued over the past decade, including themost recent and significant rulings by statesupreme courts.

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.

David J. Woll
+1-212-455-3136
dwoll@stblaw.com

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

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

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

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.

The contents of this publication are for informational purposes only. Neither this publication nor the
lawyers who authored it are rendering legal or other professional advice or opinions on specific facts
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Please click here to subscribe to the Insurance Law Alert.
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