A commentary on insurance coverage issues in Hawaii and beyond
The appellate court affirmed the trial court’s grant of summary judgment to the contractor’s insurer finding that the sumcontractor’s insurer had a duty to defend the contractor. Navigators Specialty Ins. Co. v. TBR Construction, LLC, et al., 2025 Ill. App. Unpub. LEXIS 2177 (Ill. Ct. App. Dec. 3, 2025).
Greenscape Homes, LLC was the…
The court granted partial summary judgment on the duty to defend to two additional insureds who were named as defendants in the underlying personal injury suit. In re Third St. Equity, LLC, 2025 U.S. Dist. LEXIS 234909 (E.D. N. Y. Dec. 2, 2025).
Third Street Equity LLD hired Developing NY State, LLC as…
The lower court’s decision granting the insurer’s motion to dismiss parties not named as an insured or additional insured was granted. Ocasio v. Metro Myrtle Ave, LLC, 2025 N.Y. App. Div. LEXIS 5925 (N.Y. App, Div. Oct. 22, 2025).
The plaintiff tripped and fell on a sidewalk in front of premises owned by defendants…
The court dismissed the additional insured’s complaint seeking a defense against a personal injury case. Piece Mgmt., Inc. v. Atlantic Casualty Ins. Co., 2025 U.S. Dist. LEXIS 205589 (S.D. N. Y. Oct. 18, 2025).
The underlying plaintiff, Mustafaa Dais alleged that he was injured when a glass door collapsed onto him as he exited…
The court held the policy’s Employer’s Liability Exclusion precluded coverage for the injured individual who was deemed to be an employee of the insured. Craft v. Access L.L.C., 2025 U.S. Dist. LEXIS 179794 (W.D. La. Sept. 2, 2025).
Charles Craft worked for FL Crane & Sons, Inc.. The general contractor of the project, Lemoine Company…
The court denied the insurer's motion for summary judgment on its claim that a defense was not owed to an entity not named as the insured under the policy. Safeco Ins. Co. of Am. v. Order Denying Rip Van 898, LLC, 2025 U.S. Dist. LEXIS 139269 (D. Nev. July 22, 2025).
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The federal district court determined that the insurer must defend the additional insured even though it was premature to determine whether there was also a duty to indemnify. Liberty Mutual. Fire Ins. Co. v. Acuity Mut. Inx. Co., 2025 U.S. Dist. LEXIS 121429 (D. Nev. June 26, 2025).
Royal…
The court agreed with Travelers that Lloyd's had a duty to defend the underlying personal injury case. Travelers Indem. Co. v. Underwriters at Lloyd's, 2025 U.S. Dist. LEXIS 118445 (S.D. N. Y. June 23, 2025).
Jerome Avenue owned a multi-tenant property in the Bronx, New York. Jerome Avenue leased…
In a dispute over coverage obligations between two insurers, the court rejected one insurer's claim that the other insurer was equitably estopped from denying a defense. Associated Industries Ins. Co. v. Sentinel Ins. Co., 2025 U.S. Dist. LEXIS 114423 (S.D. N. Y. June 16, 2025).
Eduardo Molina was a construction…
The appellate court reversed the lower court's denial of the insurer's motion to dismiss a claim pursued by non-insured parties. Nino & Nino Corp. v. Utica First Insurance Co., 2025 N.Y. App. Div. LEXIS 3226 (N.Y. App. Div. May 28, 2025).
Granville Wiltshire (decedent) was an employee of Door Restaurant…
