The Ninth Circuit affirmed summary judgment for defendant insurer United Specialty Insurance Company based on the admiralty doctrine of uberrimae fidei or “utmost good faith,” a doctrine sometimes used in reinsurance arrangements. The court held an insurer can invoke the doctrine to void a marine insurance contract if it can show either: (1) an intentional misrepresentation of fact, regardless of materiality, or (2) non-disclosure of a fact material to the risk, regardless of intent. Plaintiff failed to disclose the true owner of the insured vessel to the defendant, a fact that was material to the defendant’s assessment of the risk, according to the court. SW Traders, LLC v. United Specialty Ins. Co., No. 09-0778 (9th Cir. Nov. 18, 2010).