September 2026

The California Supreme Court concluded that the insureds could state a cause of action for declaratory relief regarding coverage under an excess policy even though all of the underlying policies had not yet been exhausted. Fox Paine & Co., LLC v. Twin City Fire Ins. Co., 2026 Cal. LEXIS 3942 (Cal. July 27, 2026).

The federal district court held that the insurer was obligated to defend the additional insured, rejecting the insurer’s argument that the additional insured was an indemnitee under the policy’s supplementary payments provision, negating the insurer’s having to pay defense costs. Charter Oak Fire Ins. Co. v. Liberty Mut. Fire Ins. Co., 2026 U.S. Dist.