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 ...

A recent decision from the U.S. District Court of Western District of Washington  touches on a number of important insurance coverage issues:  policy reformation, the effect of an insured’s late notice of a claim, and the insurer’s burden to prove applicability of a policy exclusion. In General Casualty Company of Wisconsin v. Reed Hein & Assoc. LLC et al., the court’s consideration of these issues resulted in opposite outcomes for two insurers. While the insured’s CGL carrier (General Casualty) successfully avoided a duty to defend, the D&O insurer (RSUI) was found to have ...

This week at the Coverage Corner, we are looking at a recent Seventh Circuit decision that offers guidance on two issues under Indiana law: (1) an excess insurer’s duty to participate in a pre-suit mediation where the underlying policy limits have not yet been exhausted but “would be” exhausted in the event of a settlement; and (2)  whether a party qualified for coverage as an additional insured based on facts outside the underlying complaint.

Background

The insurance coverage dispute in Atlanta Gas Light Company & Southern Company Gas v. Navigators Insurance Company, Case Nos ...