On February 16th, the Second Circuit held that a homeowner's insurance policy does not cover losses suffered in a Ponzi scheme. Plaintiff, a victim of Bernard Madoff's, sought recovery under her homeowner's insurance. Affirming the entry of summary judgment dismissing the claims, the Second Circuit held that plaintiff's Madoff account did not suffer a direct physical loss as required for coverage under her insurance policy. Lissauer v. Fireman's Fund Insurance Cos. (Summary Order).