The United States District Court for the Eastern District of Virginia, applying Virginia law, has held that a professional services exclusion in a policy issued to a crematorium barred coverage for a lawsuit stemming from the policyholder's mishandling of crematory remains. Bohreer v. Erie Ins. Group, 2007 WL 569901 (E.D. Va. Feb. 16, 2007). The underlying suit alleged that the policyholder contracted to cremate the plaintiff's husband's remains and mishandled those remains. The insurance policy excluded coverage for "damages due to any service of a professional nature." It did not define the phrase "professional nature." The court held that the handling, labeling and delivery of remains were all part of the professional service of cremation and were therefore within the meaning of the professional services exclusion.