Reversing an appellate court decision, the New York Court of Appeals held that an earth movement exclusion in a property policy applied unambiguously to damage arising from “man made” activity. Bentoria Holdings, Inc. v. Travelers Indem. Co., 2012 WL 5256119 (N.Y. Oct. 25, 2012). The court explained that because the exclusion specifically stated that it applied to earth movement “whether naturally occurring or due to man made or other artificial causes,” it barred coverage for damage caused by the excavation of adjacent property. In so ruling, the court distinguished Pioneer Tower Owners Ass’n v. State Farm Fire & Cas. Co., 12 N.Y.3d 302 (2009), in which the court held that an earth movement exclusion was ambiguous as to excavation-related damages. The exclusion at issue in Pioneer lacked the clarifying language set forth in Bentoria Holdings.