Reversing an earlier summary judgment ruling, the Arizona Court of Appeals recently ruled in favor of a general contractor’s status as an additional insured entitled to coverage under its subcontractor’s general liability policies. KB Home Tucson, Inc. v. Charter Oak Fire Insurance Company, No. 12-0681 (Ariz. Ct. App. Nov. 25, 2014). KB Home Tucson, Inc. (“KB”) contracted with GRG Construction Co. (“GRG”) to perform construction work at a residential subdivision in Tucson. As part of the contract with KB, GRG was required to “comply with all rules, regulations and requirements of [KB].” Thereafter, KB sent annual letters to GRG detailing KB’s minimum insurance requirements and requesting that KB be named as an additional insured on GRG’s general liability policies. In response, GRG’s brokers issued certificates of insurance to KB. After later being sued by the City of Tucson and various homeowners, who alleged property damage as a result of construction defects, KB tendered the defense of these claims to GRG’s insurers. Both insurers disclaimed coverage, asserting that KB did not qualify as an additional insured in the absence of a written contract requiring that GRG add KB as an additional insured. KB filed suit against both insurers for declaratory relief, breach of contract, and bad faith, and against GRG’s brokers for negligence, negligent misrepresentation, and fraud. After KB reached a settlement with one insurer, the trial court granted summary judgment in favor of the remaining defendants. Reversing judgment as to the remaining insurer, the appellate court held that the language of the relevant insurance policy permitted additional insured status to be conveyed by the existence of either a “written contract or written agreement.” In this case, the written documents prepared by or at the direction of KB and GRG, taken as a whole, establish such an agreement and entitle KB to coverage as an additional insured. In addition, GRG never disputed that it was required to add KB as an additional insured on its general liability policies. As to GRG’s brokers, however, the appellate court affirmed, holding that KB could not maintain its claims of negligence and negligent misrepresentation in the absence of a duty owed to KB as a non-client of the brokers. The court also held that because KB was entitled to coverage as an additional insured, the certificates of insurance had not contained any false statements or misrepresentations in order to support KB’s fraud claim.