The United States District Court for the Middle District of Louisiana recently granted an insurer’s motion for summary judgment, finding that an excess workers’ compensation and employers’ liability policy was not reinsurance and that the limit of liability of an underlying insurance policy was not relevant to the amount owed. Louisiana Commerce and Trade Association Self Insurers Fund sued National Union Fire Insurance Company of Louisiana for breach of contract. The district court to which the case was removed described the case as “a dispute between two insurance companies over the limits of liability resulting from the settlement of an intentional tort case.” LCTA provided indemnity for workers’ compensation benefits and employers liability and issued coverage to Gee Cee Group Inc. and Gee Cee Enterprises. An employee of Gee Cee was injured and filed a workers’ compensation claim and claim for intentional tort damages against Gee Cee. Gee Cee settled the intentional tort action and LCTA filed a proof of claim with National Union for $1 million, the policy limits of the National Union/LCTA policy. Of that amount, National Union paid $800,000 and then asserted that it had overpaid by $300,000 because the policy limit was actually only $500,000. Both parties moved for summary judgment. LCTA asserted that it was entitled to judgment in its favor for $200,000, and National Union asserted that it is a reinsurer that has no greater liability to LCTA than LCTA has to Gee Cee, which is $500,000. Finding the terms of the National Union/LCTA policy to be clear and unambiguous, and not reinsurance, the district court held for LCTA. Louisiana Commerce and Trade Association Self Insurers Fund v. Nat’l Union Fire Insurance Co. of Pittsburgh, No. 13-773-JJB-RLB (USDC M.D. La. Nov. 3, 2015).