Illinois federal district court relies on extrinsic evidence to rule that insurer has no duty to defend *

USA - November 16 2012
In Nautilus Ins. Co. v. Ricciardi Dev., LLC., No. 11-C-6126, 2012 WL 5471091 (N.D. Ill. Nov. 9, 2012), an Illinois federal district court granted summary judgment to an insurer who filed a declaratory judgment action, holding that the insurer had no duty to defend or indemnify its policyholder in a negligence suit under a commercial general liability policy because extrinsic evidence, which the court determined that it could consider under Illinois law, demonstrated that the policy’s completed work exclusion applied.

Co-authors: Hillary Coombs Jarvis .

First Circuit clarifies application of “reasonable diligence” coverage trigger in duty to defend context *

USA - July 13 2012
In Travelers Casualty & Surety Co. v. Providence Washington Insurance Co., No. 11-2193, 2012 WL 2821898 (1st Cir. July 11, 2012), the United States Court of Appeals for the First Circuit, applying Rhode Island law in a declaratory judgment action between two commercial general liability insurers, reversed the federal district court’s summary judgment order holding that the defendant insurer did not have a duty to defend a contribution action involving clean-up costs for the Rhode Island Centredale Manor Superfund Site.

Co-authors: Ruth S. Kochenderfer.