In a recent decision regarding insurance coverage for lost gross profit from the voluntary recall of mislabeled Sausage Breakfast Sandwiches, which inadvertently contained the flavor enhancer monosodium glutamate (“MSG”), the Eighth Circuit clarified the standard for triggering coverage and the evidence sufficient to support a damages award pursuant to an Accidental Product Contamination policy.  Hot Stuff Foods, LLC v. Houston Cas. Co., 771 F.3d 1071 (8th Cir. 2014) (Nos. 14-1192, 14-1194).  The court interpreted the policy terms “may likely result” to cover the insured’s recall of the mislabeled sandwiches, which had not caused any reported illnesses, only if there was more than a possibility, but less than a probability, that the mislabeled product would cause physical symptoms of bodily injury, sickness, disease or death, comparing the standard to “reasonably likely to result.”  In doing so, the court rejected the district court’s “possibility or a slight chance” test, which the district court found was satisfied by a showing that the recalled sandwiches could cause sickness in at least one person.  The court further held that there was a jury question as to whether consumption of the mislabeled sandwiches met the “more than a possibility, but less than a probability” standard, in light of the conflicting expert and inconclusive government reports and scientific studies.  However, the court held damages need not be retried and affirmed the district court’s denial of the insurer’s motion for judgment as a matter of law as to the amount of the jury’s award of lost gross profit.  The insured had presented testimony of two regional sales managers that all employees needed to assist with the recall, preventing the company from adequately marketing at important trade shows, which led to reduced sales.  The court held that the jury had sufficient evidence to find direct causation between the recall and the lost gross profit on new products.