HNRK Coverage Corner

This week on Coverage Corner, we revisit Adolph v. General Casualty Company of Wisconsin, a coverage action in the United State District Court for the Western District of Washington, that we previously covered here. In a decision issued on April 15, 2026, the court granted plaintiffs’ motion for reconsideration and clarified the consequences of an insurer’s denial of coverage based on an unreasonable interpretation of policy language.

Background: The Prior Summary Judgment Order

In its original summary judgment order, the Court held that the insurer, RSUI, had breached its ...

On April 6, 2026, the Ninth Circuit issued a decision in Bramblett v. Allied World Specialty Ins. Co., Case No. 25-489, holding that Allied World acted in bad faith in denying a defense to its insured based on a Sexual Abuse Exclusion, where “a conceivable basis for coverage existed” as to at least some claims asserted in the compliant.

In Bramblett, the plaintiffs alleged they were the victims of sexual misconduct by an employee of the insured, including both verbal harassment and physical misconduct.  The insured’s policy expressly covered losses arising from claims alleging ...