A commentary on insurance coverage issues in Hawaii and beyond
The Appellate Division, Supreme Court of New York, affirmed the lower court’s grant of summary judgment determining that the insurer could not challenge the judgment in the underlying case after refusing to defend the insured. Shattuck v Dryden Mut. Ins. Co., 2026 N.Y. App. Div. LEXIS 3789 (N.Y. App. Div. June 5, 2026).
The…
The court granted summary judgment to the insurer, finding it had no duty to indemnify the additional insured nor to continue its defense of the additional insured. W. Bend Mut. Ins. Co. v. Budrovich Indoor Training I, LLC, 2026 U.S. Dist. LEXIS 133776 (E.D. Mo. June 16, 2026).
Budrovich Indoor Training leased to tenants…
The Eleventh Circuit found it lacked jurisdiction to consider the insurer’s appeal of a motion to dismiss its declaratory relief action seeking a ruling it had no duty to defend. Northfield Ins. Co. v. North Brook Industries, Inc., 2026 U.S. App. LEXIS 14776 (11th Cir. May 22, 2026).
North Brook Industries, Inc. owned and operated…
The federal district court granted summary judgment requiring the insurer to defend the insured hotel in a suit involving sex trafficking of a minor. Am. Fam. Mut. Ins. Co. v. Windham Motels & Resorts, Inc., 2026 U.S. Dist. LEXIS 66641 (S.D. Ind. Feb. 25, 2026).
G.M., a minor, sued the hotel alleging that she…
The federal district court granted the insurer’s motion for summary judgment after finding there was no coverage based upon the policy’s assault and battery exclusion. Cincinnati Specialty Underwriters Ins. Co. v. Mainline Private Security, LLC, 2025 U.S. Dist. LEXIS 259938. (E.D. Pa. Dec. 26, 2025)
Mainline Private Security, LLC provided security guard services to…
Applying Texas law, the Second Circuit affirmed the district court’s judgment that the insurers had no duty to defend or indemnify the manufacturer of ghost guns and gun parts. Granite State Ins. Co. v. Primary Arms, LLC, 2025 U.S. App. LEXIS 32275 (2nd Circ. Dec. 10, 2025).
The insured, Primary Arms, sold and shipped…
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 court determined that the subcontractor’s insurer owed a defense to the additional insured general contractor in a bodily injury suit. Charter Oak Fire Ins. Co. v. Liberty Mut. Fire Ins Co., 2025 U.S. Dist. LEXIS 227712 (S.D. W. V. Nov. 19, 2025).
A.L.L. Construction, Inc. was the general contractor for a construction project.
The court found that the insurer had a duty to defend and dismissed the insurer’s motion for summary judgment. Travelers Indem. Co. of Conn. v. I.C. Refrigeration Services Inc., 2025 U.S. Dist. LEXIS 221768 (N.D. Cal. Nov. 10, 2025).
Flory Construction, Inc. sued the project owner, Highbridge, asserting claims for (1) foreclosure on mechanics…
