Successor Liability:

Liability and Coverage Implications

 

Diane L. Polscer

Thomas A. Gordon

 

I.

Introduction

With the expansion of legal remedies against corporations for the actions of purchased companies has come the increased attempt to gain insurance coverage for the actions by the predecessor corporations.  Although the insurance agreement is universally considered a contract, and interpreted as a contract, there has been a significant movement by courts to impose additional coverage responsibilities for insurers of predecessor corporations, when the successor corporation is sued.

Courts in many states have determined that an insurance policy issued to a predecessor corporation provides coverage to a successor corporation when the successor corporation is sued based upon actions by the predecessor company.  This has created a number of problems unique to this situation.  Some courts have recognized these problems and attempted to resolve them, while others have not.  This article focuses on the circumstances under which courts have found insurance coverage for successor corporations.  It will also address certain legal issues that have received little or no discussion by the courts, but which affect insurance and successor liability.

II.

Successors Generally Not Liable for Acts of Predecessors

In general, a company that purchases another company is not responsible for the liabilities of the purchased company, but there are several exceptions to this rule.

Based upon judicial decisions in almost every state, a successor is responsible for the liabilities of its predecessor under any of the following circumstances: an express assignment of liability; an express or de facto merger; a determination that the successor is a mere continuation or reincarnation of the predecessor; or a fraudulent attempt to avoid liability.[1]  When two companies merge in conformance with state statutes, then by statute, the successor company will also be liable for debts of the predecessor.[2]

Some courts also recognize successor liability in the products liability context, known as “the product line exception.”[3]  A minority of states has adopted this rule.  The product line exception is applied when the successor corporation purchases substantially all of the assets of the predecessor corporation, the products liability arises from the predecessor’s product line, the predecessor company ceases to exist so that there is no remedy against the predecessor, and the successor uses the goodwill of the predecessor.  There are variations on the required elements depending upon the jurisdiction.  A few have also adopted the continuity test as an expansion of the mere continuation exception.  Under the continuity test, the entirety of the circumstances is analyzed to determine whether the successor is liable, rather than specific requirements related to ownership and management.[4]

III.

transfer of insurance to successor May cover liabilities of predecessor

Courts in several jurisdictions have found that insurance can be transferred from a predecessor to a successor by contract or as a matter of law.

A. Transfer of Insurance May Be Effected Through Contractual Terms

Some jurisdictions focus solely on the terms of the contract or agreement between the corporations in the underlying transaction.  They do not consider the underlying tort as a source for insurance coverage, but rather focus on the arrangement between the predecessor and successor companies, and whether such arrangement is effective under the insurance agreement.

Courts have taken differing approaches in applying the contract approach.  Most first look at whether there was an intention in the underlying transaction for the policies to be transferred.  Then, even if there was such an intention, courts determine whether the insurance policy at issue allows such a transfer under the circumstances. In most cases, the right to insurance coverage is not expressed in the transaction between the corporations.  Without such express terms, there is a split of authority as to whether the insurance policy is transferred.[5]

When there is such an expression, courts will often follow it.  In Koppers Industries, Inc. v. North River Insurance Co,[6] the court found that because the asset agreement specified that the policies did not transfer to the successor corporation, this expression should be followed.  The court in Koppers also considered the fact that the predecessor corporation still existed and should maintain its right to the insurance coverage.  In Knoll Pharmaceutical, Inc. v. Automobile Insurance Co.,[7] the court found that the policies were not transferred by the asset purchase agreement to another entity and, therefore, remained with the named insured for that transaction.  The court later found that the policies transferred to a third corporation as a matter of law.

The California case Quemetco, Inc. v. Pacific Automobile Insurance Co.,[8] illustrates the principles of following the contractual transfer approach.  In Quemetco, the court refused to transfer the benefits of the predecessor’s insurance policy to the successor corporation to provide coverage for a CERCLA claim or a private class action lawsuit.  The policies in question were issued to Western Lead, which changed its name to Quemetco.  This entity sold all of its assets to St. Joe Mineral Corporation and Q Acquisition Corporation, which was a wholly owned subsidiary of St. Joe Mineral.  At that point, old Quemetco was dissolved.  Q Acquisition changed its name to Quemetco.  The court reviewed these transactions and the insurance policy itself.  It determined that the insurer had no coverage obligation towards the successor company because the transfer was before the loss and there was no consent by the insurer to the transfer.  The court also noted that the mere fact of successor liability does not lead to a conclusion that the insurance coverage also transfers to the successor.  Rather, the terms of the contract itself must be followed.  Alternatively, the court based its decision upon the fact that cleanup damages were not assessed until 1987 and “no liability passed as a matter of law” to the successor corporation at the time of the sale of the assets of the predecessor corporation.[9]  Another factor the court considered was that although the predecessor corporation was dissolved, under prior California decisions, the predecessor could still be sued and would be entitled to a defense from its insurers.  Because allowing coverage to be extended to the successor corporation would increase the risk to the insurer beyond what was bargained for, the court ruled against so extending coverage.

In response to cases imposing successor liability in product line liability cases, the California case of General Accident Insurance Co. v. Superior Court,[10] specifically rejected the application of this exception to insurance coverage.  The court found that the “insured-insurer relationship is a matter of contract.  Successor liability is a matter of tort duty and liability.”[11]  The court determined that there was a significant difference between successor liability and insurance coverage, and to “deem the successor corporation a party to insurance contracts it never signed, and for which it never paid a premium, and to deem the insurer to be in a contractual relationship with a stranger,” was improper.[12]

The second part of the analysis under the contractual transfer theory concerns the “no assignment” clause in the insurance policy.  By its terms, this clause bars the transfer of a policy without the insurer’s consent.  Courts have avoided this restriction by finding that the right to recover under a policy after a loss has occurred is an asset assignable separate from the policy and that after a loss, the policy can be assigned without insurer consent, the assignment clause notwithstanding.[13]  There is a split of authority regarding this rule; however, the weight of authority remains against applying the anti-assignment clause to situations in which the loss at issue precedes the assignment.[14]  In Egger, the insured and the claimant agreed, prior to a jury verdict that the claimant would accept an assignment of the rights under the policy in exchange for an agreement not to enforce an excess judgment.  The court found that although the agreement to assign the policy was made prior to the verdict, it was not an actual “assignment” until after the verdict, and was therefore a valid assignment of the right to recover under the policy.

In situations in which there is an actual merger in conformance with corporate forms, such as was discussed in Federal Insurance Co. v. Purex Industries, Inc.,[15] a “no assignment” clause in CGL and excess liability insurance policies did not bar transfer of policies issued to insured where assets were purchased by a wholly owned subsidiary and then absorbed into another corporation by statutory merger.  Since the rationale for the no assignment clause – preventing a risk increase to insurers – is not present in the merger context, and courts find no assignment clauses inapplicable to mergers in compliance with statutory requirements.[16]

If the no assignment clause applies to pre-loss transfers but not post-loss transfers, a court must define what the “loss” is.  The court in Red Arrow, was confronted with a claim of environmental liability, but applied the anti-assignment clause to prevent transfer of the policy without the insurer’s consent and did not discuss the timing of the loss.  However, the Quemetco court noted that the loss did not occur until after the transfer because the liability for the environmental cleanup was not assessed until after then.[17]  In contrast to Red Arrow and Quemetco, the majority view, as illustrated by B.S.B. Diversified Co. v. American Motorists Insurance Co.,[18] appears to be that “[a]fter the events giving rise to the insurer’s liability have occurred, the insurer’s risk cannot be increased by a change in the insured’s identity.”[19]

B. Insurance May Transfer Through Operation of Law

Courts have also allowed the transfer of insurance coverage where the liability for the actions of the predecessor has transferred to the successor as a matter of law.  The most common rationale under this theory is that the insurance policy follows the liability.

The majority of jurisdictions addressing the issue have found that the liability insurance policies of a merged corporation may transfer by operation of law to the surviving corporation.[20]  In finding that the surviving corporation’s rights to liability insurance had vested by virtue of the merger statute, the Brunswick court rejected the insurer’s reliance on a clause in the policy prohibiting assignment absent the insurer’s consent.[21]  The federal court noted that a “no-assignment” clause should not be applied in the absence of increased risk to the insurer.[22]

On this basis, the court observed that the insurer would not face any prejudice by operation of the assignment given that it would only be liable for covered acts that occurred during the period of the insurer’s coverage.  The court observed that it would not prevent assignment of the insurance policy absent explicit policy language prohibiting assignment of the policy through merger. [23] However, some recent cases have taken the position that liability policies do not transfer by operation of law or merger.

In Knoll Pharmaceutical Co. v. Automobile Insurance Co.,[24] the court found that once a merger is established, the successor corporation takes on all of the predecessor’s obligations and liabilities, including its insurance policies.  Knoll Pharmaceutical also addresses the issue of whether insurance policies are transferred through an asset purchase agreement.  The named insured under the policies was the subsidiary of another corporation, which, by the terms of the policy, did not have the power to transfer rights under the policy.  Through an asset purchase agreement, all of the shares in the subsidiary, and substantially all the assets, were transferred to Basfin, a third corporation.  Later the subsidiary corporation merged with Knoll Pharmaceuticals.  The court found that because the original parent company did not have the right to transfer the insurance policies, the rights to the policies remained with the original named insured and did not transfer to the new parent corporation.

A number of courts have found that when liability is transferred to a successor by operation of law, any applicable insurance policy must be transferred as well.  In Westoil Terminals Co. v. Harbor Insurance Co.,[25] the court found that a de facto merger transfers both liability and insurance covering the liability.  In that case, the successor argued for protection under the predecessor companies’ coverage based on allegations in the underlying complaint of “product line liability.”  The court first recognized that merely because a company may be liable as a successor, does not mean that the policies automatically follow the liability.  It found, however, that since the successor company had essentially the same name, the same operations as before, the same equity interests and was under the same control, it fell within the exception to the no transfer of insurance rule referred to in General Accident Ins. Co. and Quemetco.  The court concluded that since there was no longer a predecessor entity, and the insurance policies had to belong to someone, they belonged to the successor by de facto merger.

Although the general principle followed by many courts nationally is that insurance follows liability in successor liability cases, some courts have restricted that general principle to product line successor liability cases.[26]  One court has found that when the predecessor company had insurance coverage, the product line exception imposing liability on the successor is inapplicable, because the injured party can still recover from the predecessor through the insurance.[27]

In B.S.B Diversified Co. v. American Motorists Ins. Co.,[28] the court found that the insurance policies transferred by operation of law because the successor corporation was responsible for the environmental liability of predecessor.  The case is a prime example of the statement that the insurance follows the liability.  The successor corporation was assigned the policy that provided coverage for the environmental liability, which was specifically assigned in a purchase agreement.  Alternatively, the court, following the Ninth Circuit's decision in Northern Insurance, concluded that the policy transferred by operation of law because the liability transferred by operation of law.  In reaching this decision, the court expanded the holding in Northern Insurance, which only applied to product line successor liability cases, to environmental liability cases.  In Gopher Oil Co. v. American Hardware Mutual Insurance Co.,[29] the court found that the policies transferred to the successor company based upon the conclusion in the underlying matter that the successor was liable for the environmental liability of the predecessor.  The court disregarded the anti-assignment clause on the grounds that the transfer occurred after the loss, and thus did not increase the risk to the insurer.  The facts indicate that all the contamination occurred prior to the corporate transfer, but the insured did not purchase one of the properties at issue until after the policy period.  This did not affect the court’s decision.

In a case rejecting a successor corporation’s right to the benefits of a predecessor’s CGL policies for pre-purchase liability by operation of law, the court in Red Arrow Products Co. v. Employer’s Insurance of Wausau,[30] rejected the extension of the product line successor liability theory to environmental claims.  The court held that the EPA could seek recovery from both the successor and predecessor for response cost in connection with site contamination, and therefore the successor was liable for the contamination irrespective of the predecessor’s liability.  The court found that because the EPA was not prevented from seeking damages from the successor corporation independently, and because there was not the same public policy concern of taking advantage of helpless victims, transfer of the insurance policy was not warranted.  In so holding, it noted:

 

As our supreme court noted, the question is not, “Who will pay the cost of the environmental cleanup?”  Rather, the issue here is whether [successor] is an insured under the Wausau policies as a matter of contract law.  We conclude that [successor] is not.  Because [successor] never paid premiums on the policies and never bargained for the policies, there was no privity of contract between Wausau and [successor].  In addition, the policies were never assigned to [successor].[31]

 

Maryland Casualty Co. v. W. R. Grace & Co.,[32] presents another example of a court’s refusal to allow the transfer of insurance.  In rejecting the successor’s claim of coverage for pre-acquisition activities of its predecessors, the court stated:

 

In the present case . . . the underlying claimants seek relief from Grace for the time period when the Maryland policies were in effect, but before the merger.  Grace had no relationship with the claimants before the merger.  Any injury to a claimant occurred before Maryland came on the risk.  Consequently, Maryland had no duty to defend or indemnify.[33]

 

In General Accident & Insurance Co. v. Superior Court,[34] the insured argued that the insurance coverage for a corporation transferred by operation of law to the successor corporation once the successor corporation was found liable in tort for injuries arising from the predecessor’s distribution of asbestos products and, therefore, it was entitled by operation of law to the insurance coverage of its corporate predecessor.  The court rejected this argument, holding that successor liability in tort does not entitle the successor corporation by operation of law to insurance coverage of the corporation’s predecessor, because to do so would require an insurer that was never “a party to an insurance contract to be liable to an ‘insured’ that has never paid a premium or been subjected to an underwriting analysis.”[35]

The recent case of Century Indemnity Co. v. Aero-Motive Co.,[36] also rejects transfer of insurance policies by operation of law.  In that case, both a successor and predecessor were pursued for environmental cleanup damages.  The court rejected the reasoning in Northern Insurance and decided to follow the reasoning in Red Arrow and Quemetco.  It found that the successor was not named in the policies, never paid any premiums on the policies and never received an assignment of the policies, so should not receive the benefits of the policies.  The court also noted that in CERCLA cases, unlike products liability, the successor’s liability did not exist at the time of the asset sale, but arose years later when CERCLA was enacted.  In this particular case, additionally, the risk would be increased because of the potential for contribution demands from the successor against the predecessor.  Finally, the court found that even though two of the policies were assigned to the successor, the assignment was invalid because it came after the loss without consent of the insurer.  Despite the fact that the releases creating the liability occurred prior to the transfer, the liability itself did not arise until years afterward.

IV.

transfer by contract and by operation of law

The California Supreme Court recently applied another theory to the determination of whether a surviving corporation of a corporate merger was entitled to insurance coverage from the predecessor corporation.  In Henkel Corp. v. Hartford Accident & Indemnity Co.,[37] the California Supreme Court held that the surviving corporation was not entitled to a predecessor’s coverage as a matter of law because the surviving corporation’s tort liability for injuries caused by the business was assumed by contract rather than imposed by law.  Further, exceptions to the enforceability of a non-assignment clause in an insurance policy did not apply to an assignment of coverage by another corporation to the successor’s subsidiary.

The facts in Henkel are complicated.  Amchem No. 1 had two distinct product lines, both of which were insured by Aetna.  In 1977, Union Carbide acquired Amchem No. 1 by stock purchase and merger.  In 1979, Amchem No. 1 created a new corporation (Amchem No. 2).  Amchem No. 1 transferred “all its right, title and interest . . . and its domestic assets utilized in its metal working business” to Amchem No. 2.[38]  Although the 1977 contract referred to assets and liabilities, it did not specify particular assets transferred or liabilities assumed.  In 1980, Union Carbide sold all of its stock of Amchem No. 2 to Henkel in a transaction in which Henkel acquired all of Amchem No. 2’s assets and liabilities.  After Henkel purchased Amchem No. 2, these two corporations merged.  In 1986, Union Carbide sold Amchem No. 1 to Rhone Poulenc, Inc.  In 1992, Amchem No. 1 and Rhone Poulenc, Inc. merged.  Henkel succeeded to all of the rights and obligations of Amchem No. 2, and Rhone Poulenc, Inc. succeeded to all of the rights and obligations of Amchem No. 1.

In 1989, current and former Lockheed employees filed suit against Henkel and Amchem Products, Inc. alleging injuries from exposure to metallic chemicals during the period between 1959 and 1976.  Henkel tendered the defense to the insurer that had issued policies to Amchem No. 1 between 1959 and 1976, as well as to its own insurers.  All insurers denied tender of the claims.  Thereafter, Henkel settled its suit with the Lockheed plaintiffs and filed an action for declaratory relief against Amchem No. 1’s and Henkel’s own insurers.

Amchem No. 2 had assumed all the liabilities of Amchem No. 1 relating to the metallic chemical product line.  Henkel then purchased all of the stock of Amchem No. 2, which made Henkel responsible for all of Amchem No. 2’s liabilities, including those inherited from Amchem No. 1.  Henkel argued that even though it was not the corporate successor to Amchem No. 1, nevertheless, because it was responsible for Amchem No. 1’s liabilities as a matter of law it should be entitled to the benefit of Amchem No. 1’s liability insurance.

The Court of Appeals decision in Henkel held that “the right to indemnity followed the liability rather than the policy itself.  As a result, even though the parties did not assign [the predecessor’s insurance] policy in the Agreement, the right to indemnity under the policy transferred to [the successor corporation] by operation of law.”[39]

In reversing this holding, the California Supreme Court held that Henkel’s liability for injuries caused by Amchem No. 1 arose from contract and was not imposed by operation of law.  First, the court held that Henkel failed to make a showing that it was entitled to Amchem No. 1’s insurance protection as a matter of law because Henkel’s tort liability was not imposed upon it by law.  The court held that Henkel’s rights to any insurance policy benefits of Amchem No. 1 were the same as Amchem No. 2’s rights to those benefits and dependent on the terms of the 1997 contract by which Amchem No. 2 acquired the assets of Amchem No. 1.

The Henkel court relied on Oliver Machinery Co. v. United States Fidelity & Guaranty Co.,[40] and Quemetco, Inc. v. Pacific Automobile Insurance Co,[41], for the proposition that the right of a successor company to the benefits of its predecessor’s policy, even when liability is established by operation of law, turns on the interpretation of the contract.  Following the reasoning in Henkel, whether a company’s liabilities are imposed by law or were imposed through contract, that company’s right to its predecessor’s insurance policy depends upon the contract. 

The Henkel court also discussed the effect of any assignment of benefits of the policy considering the policy’s requirement to obtain the insurer’s consent before assignment.  First, the Henkel court noted that such assignments are generally valid and enforceable.  The insured argued that the assignment with consent provision is invalid because:  (1) coverage should follow liability when the liability is transferred by operation of law; and (2) under an occurrence-based liability policy, “policy benefits can be assigned without consent once the event giving rise to liability has occurred.”[42]  The court rejected the first argument because Henkel did not acquire the liabilities of Amchem No. 1 by operation of law.  It rejected Henkel’s second argument that policy benefits can be assigned without consent if the liability-causing event has occurred before the assignment, stating:

 

It is established that a provision in the contract or a rule of law against assignment does not preclude the assignment of money due or to become due under the contract or money damages for breach of contract.  Cases and commentators have applied this principle to the assignment of benefits under an insurance policy.  But even if we applied the principle to the liability policies, it does not bar [insurers] from enforcing their restrictions on assignment in the case here.[43]

 

The court went on to distinguish between matured claims at the time of assignment and claims that might arise at some time in the future.  In rejecting the insured’s argument that the “no assignment” clause should be ignored, the court said:

 

In 1979, when Amchem No. 2 assumed the liabilities of Amchem No. 1, the duty of defending insurers to defend and indemnify Amchem No. 1 from the claims of the Lockheed plaintiffs had not become an assignable chose in action.  Those claims had not been reduced to a sum of money due or to become due under the policy.  [The insurers] had not breached any duty to defend or indemnify Amchem No. 1, so Amchem No. 1 could not assign any cause of action for breach of such duty.  Consequently, Amchem No. 1 could not assign the right to defense and indemnity against such claims without the insurer’s consent.[44]

 

The Henkel court also rejected the argument that the no consent clause requires a showing of additional burden to the insurer:

 

An additional burden may arise whenever the predecessor corporation still exists or can be revived, because of the potential for disputes over the existence and scope of assignment.  If both Assignor and Assignee were to claim a right to defense, the insurer might effectively be forced to undertake the burden of defending both parties.”[45]

 

The Henkel decision represents the most recent, comprehensive analysis of the relationship between successor liability and the transfer of coverage under insurance policies to the successor corporation

V.

coverage for successor liability arises under various circumstances

Successor liability questions also arise when the company seeking insurance coverage is the parent company of a subsidiary that is being sued.  Under many circumstances, related companies are named as additional insureds.  That is not the subject of this article.  However, in situations in which the parent company is not a named insured, courts have found no coverage for the parent company.  In CertainTeed Corp. v. Federal Insurance Co.,[46] the court addressed whether a parent corporation should receive coverage as a “stockholder” in the subsidiary.  It found that CertainTeed, the parent corporation, was not a stockholder for the purposes of that insurance contract.  Alternatively, the court held that because the allegations in the complaint did not allege that CertainTeed was liable for its actions as a stockholder, CertainTeed could not claim coverage under the policy term providing coverage for stockholders only while acting as stockholders.

In Elan Pharmaceutical Research Corp. v. Employers Insurance of Wausau[47] the parties assumed that the parent company was a shareholder for the purposes of the insurance agreement.  However, the court followed CertainTeed in finding that because there were no allegations against the parent based upon an alter ego relationship or the parent’s status as the sole shareholder, the insurance did not provide coverage to the parent for claims made against it.  In Oliver Machinery Co. v. United States Fidelity & Guaranty Co.,[48] the court addressed a situation in which a successor corporation was being sued for a product manufactured by its predecessor.  The court found that the successor had the opportunity to buy insurance for injuries caused by products manufactured by its predecessor, but did not do so.  Because the insurance contract issued to the successor only provided coverage for products manufactured by the successor, the insurer had no coverage obligation.

Another situation arises when the predecessor company remains in existence and retains a specified liability.  In Pittson Co. v. Allianz Insurance Co.,[49] the court found that insurance coverage for a site cleanup remained with the company that retained the obligation to remediate the site.  In that case, a subsidiary of Pittson owned a contaminated site, and the subsidiary and all its assets, including the site, were sold to Ultamar in a stock-for-cash agreement.  As part of the agreement, Pittson agreed to retain the liability of its subsidiary for remediating the site.  The court found that the stock agreement, and a separate settlement between Pittson and Ultamar, did not involve an assumption of a liability by Pittson.  Rather, it was more a retention of the obligation to remediate the site.  The court decided that the insurance coverage remained with Pittson.

However, the case of Unigard Insurance Co. v. Leven,[50] illustrates the opposite result.  In Leven, Bruce Leven owned Bayside Waste, and then sold it to WMX Technologies.  The sale took place while lawsuits by Standard Equipment, owner of a site leased by Bayside, were pending.  In the sale of Bayside, Leven received stock in WMX in exchange for agreeing to indemnify and hold WMX harmless regarding the environmental contamination at the Standard Equipment site.  Unigard insured Bayside, and Leven in his personal capacity.  In the court’s discussion of Unigard’s duty to indemnify, it decided that the sale agreement resulted in Leven assuming personal responsibility for Bayside’s obligation through the indemnity agreement.  It found that this type of assumption was prohibited by the Unigard policy.  The court also decided that because Leven had no personal coverage for the underlying action, he could not create personal coverage through the indemnification agreement.

The Leven court also distinguished the cases that hold, in a successor context that the insurance follows the insured risk.  It determined that Leven was a non-successor, and assumed an obligation that he did not previously have.  The court’s reasoning is interesting and may form a basis for an argument that where the assumption of a liability is voluntary, there should be no transfer of the insurance policy without an express agreement to that effect.  Transfer by operation of law would only happen when the liability has also transferred through involuntary means.  However, the reasoning in Leven may also be restricted to cases in which there is a determination that the entity seeking coverage is in fact not a “successor” to the named insured.

The majority rule with respect to the effectiveness of the anti-assignment clause, as discussed above, has been followed in cases related to other policy provisions regarding various corporate forms.  Many policies exclude coverage when the insured partakes in a joint venture.  In Maryland Casualty Co. v. Reeder, [51] the court found that the fact that the insured is part of a joint venture does not determine coverage; rather, when the liability does not increase the risk to the insured, the exclusion does not apply.  In Reeder, the insurer argued that the purpose of the exclusion for joint ventures is to prevent the insurer from being held liable for unexpected risks.  The court found that it was a question of fact as to whether the insurer was aware of the joint venture at the time the policy was issued.  If the liability arises from the actions of the insured, then there is still coverage for those actions, despite participation in a joint venture.[52]

Concerns of excess insurers should also be considered in determining the availability of insurance issued to a predecessor company.  In the typical long-tail environmental liability context, both the predecessor and successor companies may potentially be liable for remedial action costs.[53]  In many jurisdictions, insurance liability is allocated among the primary insurers first, and then among the excess insurers through horizontal exhaustion.[54]  If the only policies available to the successor company are policies issued to that entity, then excess coverage may be impacted earlier than if the predecessor policies are also included.

Issues may also be raised with respect to the fate of self-insured retentions.  From a logical standpoint, if a court is willing to transfer coverage under a policy to follow the risk or loss, then the same conditions of coverage should apply to the successor corporation.  In other words, all terms of the insurance contract should be followed, including those that specify that the insurance is inapplicable until a self-insured retention or deductible is exhausted.

If a successor is granted rights to coverage under a predecessor’s policy, it should stand in the shoes of the predecessor, meaning that it is subject to the same obligations as the predecessor, including notice requirements.  Courts that follow the rule that late notice only applies when the notice is unreasonably late and the insurer is prejudiced by the late notice should consider whether it was reasonable for the predecessor not to give notice of the occurrence or claim.  That entity is the insured under the policy.  This should be analyzed especially in cases in which the successor is claiming that the anti-assignment clause in the policy is inapplicable to a prior loss.  If the predecessor was aware of the loss prior to the transfer and failed to give notice of the loss to the insurer, then the insurer should have arguments that the notice was unreasonably late and it has been prejudiced by the delay.

VI.

specific decisional analysis related to coverage for successors

From the cases discussed above, some trends regarding how courts address the transfer of insurance in successor liability cases can be discerned.

A likely first step for a court is to determine who the named and additional insureds are in the policy under which a corporation seeks coverage.  In some instances, the successor corporation may be named as an additional insured on the policy if, for example, the predecessor company was first a subsidiary company or another related entity that included the future successor as an additional insured on its policy.  Under these circumstances there is no need for further analysis by the court, since the successor would have whatever rights it was entitled to as an additional named insured under the terms of the policy.

If the successor is not an insured under the terms of the policy, courts will then look at the transaction between the successor and predecessor corporations to determine if the terms of the agreement included a transfer of insurance.  If insurance or the insurance policy at issue is specifically listed as an asset transferred to the successor corporation, courts will generally uphold the transfer of the policy.  The only caveat is that for coverage purposes, there is a split of decisions as to the strength of the typical “no assignment” clause in a policy.  A majority of courts have found that when the loss occurred prior to the transfer, the “no assignment” clause has no effect.  However, courts then disagree on what the “loss” is and what must be determined prior to transfer for the “no assignment” clause to be avoided.  A court must decide whether the actions leading to the liability are sufficient, or whether the liability itself must be established prior to the transfer to avoid the “no assignment” clause.  If there is no mention of insurance in the terms of the agreement between the two corporations, courts will look to the type of agreement, and to whether there is state law providing for the transfer of insurance under those circumstances, for example, whether the arrangement is a merger as opposed to an asset sale.  State law purely resolves this determination, although every jurisdiction has some form of merger statute that transfers all assets and liabilities to the surviving corporation.

If the court determines that the insurance is not transferred by operation of the underlying agreement, then it will determine if there is a transfer by operation of law.  This is also dependent upon the type of arrangement between the two companies.  However, it will also depend upon what theory of successor liability is asserted in the underlying case.  The majority rule still seems to be that when the liability is transferred to the successor company, insurance coverage for that liability should also be transferred.  Courts typically find that under these circumstances there is no additional risk to the insurer, and that equity favors the insurance following the liability.  However, recent cases have noted that in many circumstances the risk is increased because then both the successor and predecessor are receiving coverage for the same liability.  The cases of Henkel and Century Indemnity may signal a shift toward narrowing the circumstances under which an insurance policy issued to a predecessor may be transferred to a successor corporation.

VII.

CONCLUSION

            The issue of how to treat insurance coverage for the liability of a successor corporation will only increase in importance as corporations consolidate and become more global.  There remains disagreement among courts nationwide as to what circumstances are required to allow the transfer to a successor corporation of an insurance policy originally issued to a predecessor.  Courts do agree that when the transfer of insurance is included in the agreement between successor and predecessor, there is a presumption that insurance policies will be transferred.  The only hurdle in this circumstance is the no assignment clause that is included in most insurance policies.  Courts have generally avoided this restriction when the insurance is transferred after the loss at isue.  The general rule courts follow is that if the transfer of the policy does not increase the insurer’s risk, then it should be allowed, the no assignment clause notwithstanding, although this is by no means a universal rule.  Furthermore, courts disagree as to what constitutes the “loss.”

            When there is no express transfer of insurance policies, some courts have allowed a transfer of coverage by operation of law. Under a general theory that insurance should follow the liability, courts have allowed coverage to a successor when the liability of the predecessor is transferred as a matter of law.  Several courts, however, have criticized this theory.  Although the majority that have addressed this issue still allow transfer of insurance by operation of law, recent decisions may signal a trend against allowing insurance coverage merely because the successor may be liable for the acts of the predecessor.  Those decisions have emphasized the difference between the tort concepts that allow transfer of liability and the contract concepts underlying insurance coverage.  Although insureds may still point to the slight majority of courts allowing transfer of coverage by operation of law, insurers can focus on recent cases as an indication of the current trend.


Appendix

State-by-State Survey of Issues

A necessary prerequisite to the transfer of insurance is the transfer of underlying liability.  The following is a survey of state cases discussing successor liability generally and the transfer of insurance.

 

Alabama

Alabama courts follow the general rule that a purchasing corporation is not liable for the liabilities of a selling corporation.  They have also recognized the four common exceptions to this general rule:  (1) express agreement, (2) de facto merger or consolidation, (3) fraudulent attempt to escape liability, and (4) the new corporation a mere continuation of the old.[55]  Continuation of the same product line as the predecessor corporation is a factor in determining whether the new corporation is a “mere continuation.”[56]  When there is an express disclaimer of liability for the transferee corporation, liability is not transferred.[57]

In the context of an asset purchase when the purchasing company assumed the liability for product liability only to the extent not covered by the seller’s insurance policy, the court found that because the seller had not been removed as a named insured on the policy in effect at the time of the accident, the seller’s insurer was liable for the injury claim.[58]  No Alabama courts have discussed the transfer of an insurance policy by operation of law or through means other than an express agreement.  However, they have followed the general rule and found that an anti-assignment clause in a policy is not effective when the loss happens prior to the assignment.[59]

 

Alaska

Alaska courts have recognized the general rule against successor liability and the four standard exceptions to that rule.[60]  The Alaska Supreme Court has also determined that the “continuity of enterprise” exception is applicable as an expansion of the “mere continuation” exception where there is not a continuity of shareholders, but other factors indicate that the new company is a continuation of the old.[61]  The Savage Arms court refused to consider whether the “product line exception” was also available under Alaska law.

Alaska courts have not addressed a situation in which a successor corporation was seeking coverage under a policy issued to a predecessor company.

 

Arizona

Under Arizona law, a sale of assets does not lead to successor liability unless there is an agreement to that effect, the transaction is a merger or consolidation, there is a mere continuation of the company, or there is fraud.[62]  In Winsor v. Glasswerks PHX, L.L.C.,[63] the court refused to expand successor liability to include the product line exception or the “community of enterprise” theory, instead deferring to the legislature to determine if successor liability should be expanded in the products liability context.

Although Arizona state courts have not addressed the issue of transferring insurance policies, in Insurance Co. of North America v. Snyder Moving & Storage, Inc.,[64] the Ninth Circuit decided, interpreting Arizona law, that absent an agreement to the contrary, a successor company generally is not entitled to insurance coverage under the policies of the predecessor.  The court recognized that there are exceptions in the context of environmental and product liability, but that Arizona courts had not recognized any of them.  Arizona courts have also determined that anti-assignment clauses are invalid when the loss has occurred prior to transfer.[65]

 

Arkansas

There are no case establishing successor liability or determining when insurance policies are transferred to a successor corporation.

 

California

California follows the general rule against successor liability and the four principal exceptions where:  “(1) there is an express or implied agreement of assumption, (2) the transaction amounts to a consolidation or merger of the two corporations, (3) the purchasing corporation is a mere continuation of the seller, or (4) the transfer of assets to the purchaser is for the fraudulent purpose of escaping liability for the seller's debts.”[66]  A fifth exception to the general rule of successor non-liability was created by the supreme court in Ray, and has become known as the “product line successor” rule because, in certain limited situations, a person injured by the predecessor’s product is given a remedy against the successor corporation.[67]

As discussed extensively above, California has had numerous occasions to address the circumstances under which an insurance policy will transfer to a successor corporation.[68]

 

Colorado

Colorado courts have adopted the standard rule against successor liability and the four principal exceptions to this rule.[69]  Colorado has limited the application of the “mere continuation” exception to situations in which there is a continuity of shareholders, managers and directors, not where there is a continuation of the business operations only.[70]  Furthermore, Colorado has rejected the “product line exception” on the grounds that a successor corporation should not be liable for the acts of another merely because it can afford to pay for them.[71]  However, the Johnston court did note that this situation was different from other cases involving the product line exception because the corporation alleged to be liable was not the direct successor and did not cause the termination of the injured party’s rights against the predecessor corporation.

Colorado follows the general rule that contracts are assignable, but that if there is an express prohibition against assignment in the contract, that term is enforced.[72]  However, the Parrish court recognized the rule that “assignments of post-loss benefits are usually found to be valid regardless of any non-assignment clause in the policy.”[73]  No Colorado decisions address the issue of the transfer of insurance to a successor through operation of law.

 

Connecticut

Regarding successor liability, Connecticut follows the general rule that a corporation purchasing the assets of another is not obligated to assume its liabilities unless there is intent to do so, merger, “mere continuation” or fraud.[74]  It also follows the “product line exception” transferring liability when the successor acquires substantially all of the transferor’s assets, when the successor holds itself out as a continuation, and the transferee is benefiting from the goodwill of the transferor.[75]

In the context of insurance policies, Connecticut courts have accepted evidence that the insurance policies were not intended to be transferred to a successor corporation as part of an asset purchase agreement.[76]  The court in R.E.O. did not address whether the policies could have transferred under an operation of law theory.

 

Delaware

Delaware courts follow the general rule and standard exceptions of successor liability.[77]  Furthermore, they narrowly interpret the continuation theory of successor liability, limiting its application to situations in which there is the appearance that the same legal entity is continuing under a different name, including the same “legal person” operating the company.[78] 

When an agreement includes a term assigning rights under operation of law, this includes a merger.[79]  In that case, there was a clause in an insurance agreement between two companies concerning the ownership of historical insurance policies that precluded transfer to another party through merger without the consent of the other party to the insurance agreement.  The court found that there was a merger, and then applied the Delaware rule that when anti-assignment clauses do not specifically prohibit the transfer or property rights, and “where performance by the original contracting party is not a material condition and the transfer itself creates no unreasonable risks for the other contracting parties, the court should not presume that the parties intended to prohibit the merger.”[80]  Although there are no Delaware cases addressing this rule regarding an anti-assignment clause in an insurance policy, the same standard may be used.

 

Florida

Florida follows the general rule against successor liability and its standard exceptions.[81]  It has refused to adopt the “product line exception” to successor liability.[82]

In the context of the transfer of mortgage insurance, a Florida court enforced the provisions of the policy prohibiting the assignment of the policy without the insurer’s consent,[83] although Florida courts have also recognized that the no assignment clause in a policy does not bar assignment after a loss.[84]  Florida has not addressed the issue of transfer of an insurance policy by operation of law.

 

Georgia

Georgia law follows the general rule against successor liability, with the standard exceptions to this rule.[85]  Georgia has adopted a “product line” exception when the successor continues to manufacture the same type of product, carries over the experience and expertise of the transferor, and is in a better position to assume the liabilities of the product’s manufacture.[86]

Regarding the anti-assignment clause, Georgia statutes allow insurers to limit the assignability of their policies.[87]  However, Georgia cases allow the transfer of the policy after the loss, regardless of an anti-assignment clause.[88]  Georgia courts have also found that when the transfer does not affect the risks taken by the insurer, the clause should not apply.[89]

Hawaii

Under Hawaii law, successor liability is only allowed when (1) there is an express or implied agreement to that effect, (2) when the transaction amounted to a consolidation or merger, (3) when the transaction was fraudulent or when elements of good faith transfer are lacking, and (4) when the successor is a mere continuation of the predecessor.[90]  Hawaii courts have not addressed the product line exception to successor liability.  They have also not discussed successor liability in the context of insurance coverage.

Idaho

Idaho courts have not addressed the issue of successor liability or the transfer of insurance policies to a successor corporation.

Illinois

Illinois also follows the general rule against successor liability and the four standard exceptions to this rule.[91]  Under Illinois law, for the mere continuation exception to apply there must be a continuation of the corporate entity of the predecessor, not merely a continuation of the business operations.[92]  Illinois courts have also rejected adopting the “product line” exception.[93]

A court interpreting Illinois law has determined that when a merger of corporations does not increase the risk to the insurer, the policy in the predecessor company is transferred to the successor.[94]  In Knoll a policy was issued to a subsidiary of a company.  The shares in the subsidiary were sold to another company.  The court ruled that the parent company had no authority under the insurance policy to transfer the policy because it was not a named insured.  The court also found that the parent company had no authority under the asset purchase agreement to transfer the policies of the subsidiary based on the language of that agreement.  The subsidiary then merged with Knoll Pharmaceutical.  The court found that the policy did transfer to Knoll as a result of the merger.  The court reached this conclusion based on the facts that because there was a merger, the liabilities transferred to the successor, and that since the insurance policies were part of the obligations of the subsidiary, the transfer did not increase the risk to the insurer.  The court also ruled that because the transfer was completed through a statutory merger, the policy’s anti-assignment clause did not apply.  It decided that the risk was not increased because the policy would only be effective against claims against the surviving corporation arising out of the covered acts of the predecessor.

 

Indiana

Under Indiana law, the general rule against successor liability applies, as do the four basic exceptions to this rule.[95]

Indiana courts have not discussed the transfer of insurance through operation of law, although a very old Indiana case decided that when one company sells all of its property to a new one, but the effect is not a merger, and the selling company remains in existence, the purchasing company is not entitled to coverage under policies issued to the predecessor company.[96]

 

Iowa

Iowa recognizes the general rule against successor liability and the four common exceptions to this rule.[97]  Iowa courts have also rejected an expansion of the “mere continuation” exception to include situations in which there is a continuity of the selling company’s operations, rather than the selling’s company’s ownership and management, known as the “totality of the circumstances” approach.[98]  Iowa courts have also rejected the “product line” exception as an expansion of successor liability.[99]

There are no Iowa cases discussing the transfer of insurance policies to successor corporations.

 

Kansas

Kansas follows the general rule against successor liability and the four general exceptions to this rule.[100]  Kansas also imposes successor liability in the products liability situation when the successor has knowledge of the defect and has a continuing relationship with the predecessor’s customers.[101]

Kansas courts have not addressed how the transfer of insurance policies is handled in the successor liability context.  However, Kansas courts have applied the rule that the no assignment clause does not bar a transfer after the loss, meaning the events leading to the insured’s liability have occurred.[102]

 

Kentucky

Kentucky follows the general rule against successor liability and the four principal exceptions to this rule.[103]  Kentucky courts have not addressed the transfer of insurance issue.

 

Louisiana

Louisiana courts have recognized the general rule against successor liability, as well as exceptions for express or implied agreement, fraud, or mere continuation.[104]  Thus far, no Louisiana court has expressly adopted or rejected the product line theory of successor liability.

 

Maine

Maine’s law of successor liability states that “absent a contrary agreement by the parties, or an explicit statutory provision in derogation of the established common law rule, a corporation that purchases the assets of another corporation in a bona fide arm’s length transaction is not liable for the debts or liabilities of the transferor corporation.”[105]  Maine has not adopted the product line exception to successor liability.[106]  Maine has not addressed any case related to insurance coverage in the successor liability context.

 

Maryland

Maryland recognizes the general rule against successor liability and the four exceptions to that rule.[107]  However, Maryland does not recognize the exception for continuity of enterprise, only continuity of entity where there is a continuity of managers and ownership.[108]  Maryland courts have not addressed the product line exception or how insurance is handled in a corporate transaction.

 

Massachusetts

Massachusetts adheres to the standard rule against successor liability and the four standard exceptions to that rule.[109]  Massachusetts appears to have a more relaxed rule regarding the mere continuation test, as it has indicated that total shareholder continuity is not required.[110]

Under Massachusetts law, “[w]hen acquisition is accomplished by stock purchase, all legal attributes of the acquired entity continue,” including retention of insurance policies issued to the predecessor company.[111]

 

Michigan

Michigan follows the general rule against successor liability with the four standard exceptions.[112]  However, Michigan has also adopted the product line exception when there is a continuity of management, personnel, location and assets, when the selling corporation ceases its business operations, when the selling corporation dissolves, when the purchasing company assumes the liabilities necessary for the continuation of normal operations, and when the purchasing company holds itself out as the effective continuation of the predecessor corporation.[113]  A continuation of the product line is not sufficient; there must be a continuity of the enterprise.[114]

In the context of workers’ compensation, in Safeco Insurance Co. v. Pontiac Plastics & Supply Co.,[115] the court found that there was a factual dispute as to whether the policies transferred because there was no evidence of an express agreement to that effect, but the effect of the asset purchase agreement was that the successor company would assume the predecessor’s business operations.  In the recent case of Century Indemnity Co. v. Aero-Motive Co.,[116] the court had the opportunity to analyze the transfer of insurance in successor liability.  The court rejected the reasoning in Northern Insurance and decided to follow the reasoning in Red Arrow and Quemetco.  It found that under Michigan law, insurance policies would not transfer by operation of law and that any assignment of the policies was invalid because the “loss” did not happen until liability was imposed for the acts of the predecessor, which happened years after the transfer.

 

Minnesota

Minnesota courts have found that the purpose of a no assignment clause is to protect the insurer from an increase in risk.[117]  When there is an assignment of a loss that has occurred prior to the transfer, then the no assignment clause is ineffective.  Only when there is an attempt to transfer the policies prior to a loss will the no assignment clause be effective.[118]  The Gopher Oil court also rejected an argument by the insurer that the loss could not have occurred until after the enactment of CERCLA because of prior decisions that in the CERCLA context the loss occurs at the time of contamination.[119]

 

Mississippi

Mississippi follows the general rule against successor liability and the four standard exception to this rule.[120]  In Huff, the court found that the product line exception was a valid theory of successor liability, but refused to apply it to the facts of that case because not all of the elements were met.

 

Missouri

Missouri has adopted the general rule against successor liability and the standard four exceptions to that rule.[121]  Missouri courts have rejected the product line rule as an additional exception to successor liability.[122]

 

Montana

Montana courts have not extensively addressed successor liability.  However, the general rule against successor liability has been recognized, as has the exception for situations in which the successor assumes the liability expressly or by implication.[123]

 

Nebraska

Nebraska recognizes the standard rule against successor liability and the four exceptions to that rule.[124]  It has not adopted the product line exception because the successor did not create the risk and there is no public policy justification for imposing the liability.[125]

In the context of an actual merger between companies under Nebraska statute, the insurance policies also transfer to the successor corporation by operation of law.[126]  The Paxton & Vierling court also found that the no assignment clause was not a bar to the transfer because the loss occurred prior to the merger of the corporations.

 

Nevada

Nevada courts have not directly addressed the issue of successor liability.  However, two federal decisions indicate that Nevada would follow the lead of the California Supreme Court in this context.[127]

Although Nevada courts have not addressed the issue of the transfer of insurance policies to a successor, the court has determined that a liability policy is the asset of a corporation.[128]

 

New Hampshire

New Hampshire courts have rejected expanding successor liability to include the product line exception.[129]  The state does recognize the general rule and the four common exceptions to that rule.[130]

In Total Waste Management Corp. v. Commercial Union Insurance Co.,[131] the federal district court discussed the transfer of insurance policies to successor corporations.  It found that since the new company was determined to be the successor in the underlying action, that new company should also receive the rights of the predecessor.  The court was also influenced by the fact that the loss occurred prior to the asset transfer to the new company.

 

New Jersey

New Jersey has adopted the product line exception to successor liability.[132]  Liability is imposed on the successor when the new corporation continues the same product line and the original manufacturer is no longer in business.  Liability is also imposed when the injury giving rise to the liability occurs before the transfer of assets.[133]  As well as the product line exception, New Jersey recognizes the four general exceptions to successor liability.[134]

Courts interpreting New Jersey law have found that as a matter of law, an insurance policy is transferred when two companies merge, along with other assets involved in the transaction.[135]

 

New Mexico

New Mexico adopted the general rule against successor liability and the four main exceptions.[136]  It has also adopted the product line exception.[137]  However, New Mexico courts have not applied the rules related to the transfer of insurance coverage.

 

New York

New York has adopted the general rule of successor liability and the four standard exceptions.[138]  In Schumacher, the court found that because the original manufacturer of the machine that caused the injury survived after an asset purchase agreement by the successor company, the successor was not a mere continuation of the predecessor.  Furthermore, the status of the product line exception is unclear under New York law, with two appellate courts reaching opposing positions.[139]  It should be noted that the court in City of New York rejected the reasoning in Hart on the grounds that Schumacher rejected the application of the product line theory of successor liability.

New York courts may allow an insurance policy to be transferred to a successor corporation when there is a merger of the two companies, when the new company is regarded as the legal successor company through asset purchase, or when the new company has been assigned the rights under the policy.[140]  The court reached its decision that there was no coverage for the successor corporation by determining that the insurer never insured the successor company, and “did not become the [successor’s] insurance carrier by virtue of plaintiff's acquisition of the business and properties” of the former corporation.[141]  In addition, the court found no evidence that the insurer is obligated to the successor company under an assignment or “under a successor-enterprise liability theory, since there was no merger of companies as a result of the agreement dated July 12, 1977.”[142]  This reasoning was followed in Employers Insurance of Wausau v. Duplan Corp.,[143] where the court stated:

 

Courts have permitted entities that are not named insureds to invoke rights under an insurance policy in certain narrow circumstances, such as when the party seeking coverage (1) is the surviving corporation in a merger with the insured; (2) is legally regarded as the corporate successor of the insured through purchase or transfer of the insured's assets; or (3) has been assigned the insured's rights in the policy.

 

As in EM Industries, the court in Duplan Corp. did not find evidence of any of these three methods of transferring an insurance policy to a successor entity.

New York courts have long held that the transfer of a claim on a policy after the loss does not violate the no assignment clause in the standard policy.[144]

 

North Carolina

North Carolina follows the general rule against corporate succession with the four principal exceptions.[145]  North Carolina courts have refused to expand the “mere continuation” exception into a broader “substantial continuation” test that has evolved in CERCLA and other areas when there is a substantial public policy concern.[146]  There are no cases related to the transfer of insurance and successor liability.

 

North Dakota

North Dakota follows the general rule against successor liability and the four main exceptions.[147]  It has refused to adopt the product line exception.[148]  North Dakota courts have not addressed the issue of insurance and successor liability.

 

Ohio

Ohio follows the general rule against successor liability and the four principal exceptions.[149]  Ohio courts have declined to expand successor liability to include the product line exception.[150]  There is a difference of opinion among Ohio courts as to the application of the expanded view of the mere continuity test to include factors beyond continuity of shareholders and directors.[151]  There are no Ohio cases involving insurance and successor liability.

 

Oklahoma

Oklahoma follows the general rule against successor liability and the four principal exceptions.[152]  Oklahoma has rejected the application of the product line exception.[153]  Oklahoma courts have not addressed whether an insurance policy is transferred with assets in a successor liability context.

 

Oregon

Oregon courts follow the general rule against successor liability with its four principal exceptions.[154]  Federal courts interpreting Oregon law have found that state courts would not adopt the product line exception to successor liability.[155]  One federal court has found that when a debtor’s interest in a policy is transferred involuntarily, by operation of law, then the prohibition against transfer in the policy is not effective. [156]

 

Pennsylvania

Pennsylvania has adopted the general rule against successor liability and its four principal exceptions.  In addition, the state has adopted an exception when transfers are not made with adequate consideration or provision for the predecessor’s creditors, or when the successor continues a product line of the predecessor essentially unchanged.[157]

A Pennsylvania court found that there was a duty to defend when an insurer refused to defend based on liabilities the insured was found to have assumed through successor liability.[158]  Federal courts in Pennsylvania have also found that when there is a sale agreement that purports to transfer the insurance rights to the successor company, the successor is entitled to coverage under those policies to the same extent that the predecessor was entitled. [159]  When there is a statutory merger, there is a similar transfer of rights to the predecessor’s insurance policies.[160]  The Brunswick court rejected application of the no assignment clause because there would be no increased risk to the insurer since its only coverage obligation was for claims against Brunswick arising out of covered acts by the predecessor.  However, the mere transfer of title to the property insured by a general liability policy does not necessarily transfer the policy.[161] 

 

Rhode Island

Rhode Island recognizes the general rule against successor liability, the four principal exceptions, and an exception where “the transfer renders the transferor incapable of paying its creditors because it is dissolved either in fact or by law.”[162]  The additional exception would not apply when a judgment was rendered after the transfer and the successor had no knowledge of the possibility of such a judgment.[163]  Rhode Island also takes a broader view of the mere continuation test, involving factors including transfer of assets, less than adequate consideration, continuation of business operations, at least one shareholder or director in common, and inability of the transferor to satisfy creditors.[164]

 

South Carolina

South Carolina courts have not directly addressed the issue of successor liability, but have recognized that liability continues when the successor has acquired substantially all of the assets of the predecessor.[165]  South Carolina has also not addressed the issue of insurance and successor liability.

 

South Dakota

South Dakota has adopted the general rule against successor liability and the four principal exceptions.[166]  Although not directly rejecting the product line exception, the court in Hamaker v. Kenwel-Jackson Machine, Inc.,[167] agreed with the Downtowner court in North Dakota that the new exception would not be appropriate.  Regarding the transfer of insurance policies, in interpreting South Dakota law, the Eighth Circuit has found that when a policy is transferred by operation of law, such as in bankruptcy, there is no more risk assumed by the insurer, and therefore the no assignment clause would not apply.[168]

 

Tennessee

There are no cases discussing successor liability or the transfer of insurance policies.

 

Texas

Texas courts have recognized the general rule against successor liability and its four principal exceptions.[169]  Texas courts have rejected adopting the product line exception to successor liability.[170]

 

Utah

Utah follows the general rule against successor liability and the four principal exceptions to this doctrine.[171]  Utah courts have not addressed the product line exception nor whether insurance policies are transferred in the context of successor liability.

 

Vermont

Vermont follows the general rule of no successor liability in the absence of a statutory merger, as well as the four standard exceptions to this rule.[172]  Vermont has rejected the product line exception as well as the broader community of enterprise theory for successor liability.[173]  There are no cases addressing the treatment of insurance policies in the successor liability context.

 

Virginia

Virginia follows the general rule against successor liability with the four principal exceptions to this rule.[174]  Virginia has rejected the product line and expanded mere continuation exceptions to the rule.[175]  Its courts have not addressed insurance and successor liability.

 

Washington

Washington follows the general rule against successor liability and the four exceptions to this rule.[176]  It has adopted the product line exception when a successor is liable if substantially all of the assets have been transferred; the transferee holds itself out as a continuation of the transferor, including the same product line under the same name; and, the transferee benefits from the goodwill of the predecessor.[177]

Courts interpreting Washington law have found that an insurance policy transfers by operation of law when there is a transfer of assets and successor liability, but the coverage only affects pre-sale activities of the predecessor company.[178]  The B.S.B. Diversified court also found that the insurance policies transferred through the agreement between the predecessor and successor because it indicated an intention to transfer all assets and liabilities arising prior to the sale.[179]  However, when the owner of a predecessor corporation assumes environmental liability, it is not entitled to coverage under the policies issued to the predecessor corporation.[180]

 

West Virginia

West Virginia recognizes the general rule against successor liability and the four general exceptions to this rule.[181]  Its courts have not addressed the product line exception or the transfer of insurance policies in successor liability.

 

Wisconsin

Wisconsin follows the general rule against successor liability with the four principal exceptions.[182]  The court in Fish also rejected the application of the product line exception in Wisconsin law.

In the context of insurance coverage, in Red Arrow Products Co. v. Employers Insurance of Wausau,[183] the court found that because the new company did not bargain for the defense duty and did not pay premiums for it, the insurer had no duty to defend the successor corporation. In its reasoning, the court rejected the argument that insurance should follow the liability, or that the product line exception provided justification for the transfer.

 

Wyoming

There are no cases on this issue in Wyoming.


ENDNOTES

 



           Submitted by the authors on behalf of the FDCC Insurance Coverage Section.

[1]           See, e.g., Tucker v. Paxson Mach. Co., 645 F.2d 620 (8th Cir. 1981); Schumacher v. Richards Shear Co., 451 N.E.2d 195 (N.Y. 1983); Brockman v. O’Neill, 565 S.W.2d 796 (Mo. Ct. App. 1978).

[2]           See, e.g., Cal. Corp. Code § 1107 (2004); 8 Del. Code Ann. tit. 259 (2004); 805 Ill. Comp. Stat. 5111.50 (2004); Mich. Comp. Laws § 450.1736 (2004); N.J. Stat. Ann. 14A:10-6 (2004); N.Y. Bus. Corp. Law § 906 (2004); Or. Rev. Stat. § 60.497(1)(c) (2004).

[3]           See, e.g., Ray v. Alad Corp. 560 P.2d 3 (Cal. 1977); Ramirez v. Amsted Indus., Inc., 408 A.2d 818 (N.J. Super. Ct. App. Div. 1979).

[4]           Cyr v. B. Offen & Co., 501 F.2d 1145, 1151-53 (1st Cir. 1974); Turner v. Bituminous Cas. Co., 244 N.W.2d 873, 883-84 (Mich. 1976).

[5]           Compare B.S.B. Diversified Co. v. Am. Motorists Ins. Co., 947 F. Supp. 1476, 1480 (W.D. Wash. 1996) (policy transferred without specific terms) and Ins. Co. of N. Am. v. Snyder Moving & Storage, Inc., 52 Fed. Appx. 899, 2002 WL 31748606 (9th Cir. 2002) (no transfer of policies because not specifically mentioned).

[6]           No. 94-1706 (W.D. Pa. Mar. 5, 1996), aff’d, 103 F.3d 113 (3d Cir. 1996) (unpublished disposition) discussed in, Joseph W. Hovermill & Angela N. Whittaker, Without Consent: Establishing A Corporate Successor’s Rights to the Predecessor’s Insurance Coverage, 37 Tort & Ins. L.J. 105 (2001).

[7]           167 F. Supp. 2d 1004 (N.D. Ill. 2001).

[8]           29 Cal. Rptr. 2d 627 (Ct. App. 1994).

[9]           Id. at 630.

[10]          64 Cal. Rptr. 2d 781 (Ct. App. 1997).

[11]          Id. at 785.

[12]          Id.

[13]          See, e.g., Better Constr., Inc. v. Nat’l Union Fire Ins. Co., 651 So. 2d 141, 142 (Fla. Dist. Ct. App. 1995); Gimbels Midwest, Inc. v. Northwestern Nat'l Ins. Co., 240 N.W.2d 140 (Wis. 1976) (assignment after loss upheld); 3 Lee R. Russ & Thomas F. Segalla, Couch on Insurance §35:7 (3d ed. 2004).

[14]          See Egger v. Gulf Ins. Co., 2002 WL 31053835 (Pa. Com. Pl., Sept. 11, 2002) (citing majority rule).

[15]          972 F. Supp. 872, 890 (D.N.J. 1997).

[16]          See Brunswick Corp. v. St. Paul Fire & Marine Ins. Co., 509 F. Supp. 750, 753 (E.D. Pa. 1981).

[17]          Quemetco, Inc. v. Pac. Auto. Ins. Co., 29 Cal. Rptr. 2d 627 (Ct. App 1994).

[18]          947 F. Supp. 1476, 1481 (W.D. Wash. 1996).

[19]          Id. at 1479 (citation omitted); see also, SCA Disposal Servs. v. Cen. Nat’l Ins. Co., No. 900393C, 1994 Mass. Super. LEXIS 617, *12 (Mass. Super. Ct. 1994) (noting that courts have justified overriding the “no-assignment” clause of the policy because such a transfer does not increase the risk to the insurer when the coverage transferred is limited to pre-acquisition occurrences); Bolz v. State Farm Mut. Auto. Ins. Co., 52 P.3d 898, 903 (Kan. 2002); Egger v. Gulf Ins. Co., 2002 WL 31053835 (Pa. Com. Pl., Sept. 11, 2002) (actual assignment did not happen until after verdict, so after “loss”).

[20]          See Brunswick Corp. v. St. Paul Fire & Marine Ins. Co., 509 F. Supp. 750, 753 (E.D. Pa. 1981); Aetna Life & Cas. Co. v. United Pac. Reliance Ins. Cos., 580 P.2d 230 (Utah 1978).

[21]          See, e.g., Brunswick Corp., 509 F. Supp. at 752-53.

[22]          Id. at 753 (citing Paxton & Vierling Steel Co. v. Great Am. Ins. Co., 497 F. Supp. 573 (D. Neb. 1980)).

[23]          See also, Sharon Steel Corp. v. Aetna Cas. & Sur. Co., 931 P.2d 127, 139 n.15 (Utah 1997) (observing that a surviving corporation which is held responsible for the predecessor corporation’s liabilities pursuant to a state merger statute should also enjoy the predecessor corporation’s protections from such liabilities).

[24]          167 F. Supp. 2d 1004 (N.D. Ill. 2001).

[25]          86 Cal. Rptr. 2d 636 (Ct. App. 1999).

[26]          See, e.g., N. Ins. Co. v. Allied Mut. Ins. Co., 955 F.2d 1353 (9th Cir. 1992), cert. denied, 505 U.S. 1221 (1992).

[27]          See Federal Ins. Co. v. Glenn D. Livelsberger, Inc., 868 F. Supp. 686, 690 (M.D. Pa. 1994).

[28]          947 F. Supp. 1476 (W.D. Wash. 1996).

[29]          588 N.W.2d 756, 763-64 (Minn. Ct. App. 1999).

[30]          607 N.W.2d 294, 302 (Wis. Ct. App. 2000).

[31]          Id. at 303.

[32]          794 F. Supp. 1206 (S.D.N.Y. 1991), rev. on other grounds, 23 F.3d 617 (2d. Cir. 1994).

[33]          Id. at 1232 (citation omitted).

[34]          64 Cal. Rptr. 2d 781 (Ct. App. 1997).

[35]          Id. at 788.

[36]          318 F. Supp. 2d 530 (W.D. Mich. 2003).

[37]          62 P.3d 69 (Cal. 2003).

[38]          Id. at 71.

[39]          Id. at 72 (quotation omitted).

[40]          232 Cal. Rptr. 691 (Ct. App. 1986).

[41]          29 Cal. Rptr. 2d 627 (Ct. App. 1994).

[42]          Henkel, 62 P.3d. at 75.

[43]          Id. (citations omitted) (emphasis deleted).

[44]          Id. (citations omitted).

[45]          Id. (citations omitted).

[46]          913 F. Supp. 351 (E.D. Pa. 1995).

[47]          144 F.3d 1372 (11th Cir. 1998).

[48]          232 Cal. Rptr. 691 (Ct. App. 1986).

[49]          905 F. Supp. 1279 (D.N.J. 1995).

[50]          983 P.2d 1155 (Wash. App. 1999), rev. den., 999 P.2d 1263 (Wash. 2000).

[51]          270 Cal. Rptr. 719 (Ct. App. 1990).

[52]          See Scottsdale Ins. Co. v. Essex Ins. Co., 119 Cal. Rptr. 2d 62 (Ct. App. 2002).

[53]          See, e.g., Red Arrow Products Co. v. Employers Ins. of Wausau, 607 N.W.2d 294 (Wis. Ct. App. 2000).

[54]          See, eg., Stonewall Ins. Co. v. City of Palos Verdes Estates, 54 Cal. Rptr. 2d 176 (Ct. App. 1996).

[55]          See Andrews v. John E. Smith’s Sons Co., 369 So. 2d 781, 785 (Ala. 1979).

[56]          Brown v. Economy Baler Co., 599 So. 2d 1 (Ala. 1992).

[57]          See Asher v. KCS Int’l, Inc., 659 So. 2d 598, 601 (Ala. 1995).

[58]          See EBSCO Indus., Inc. v. Royal Ins. Co. of Am., 775 So. 2d 128 (Ala. 2000).

[59]          See Alabama Farm Bureau Ins. Co. v. McCurry, 336 So. 2d 1109, 1113 (Ala. 1976).

[60]          See Savage Arms, Inc. v. Western Auto Supply Co., 18 P.3d 49 (Alaska 2001).

[61]          Id. at 55-57.

[62]          See A.R. Teeters & Assocs., Inc. v. Eastman Kodak Co., 836 P.2d 1034, 1039 (Ariz. Ct. App. 1992).

[63]          63 P.3d 1040 (Ariz. Ct. App. 2003).

[64]          52 Fed. Appx. 899 (9th Cir. 2002).

[65]          See St. Paul Fire & Marine Ins. Co. v. Allstate Ins. Co., 543 P.2d 147, 149 (Ariz. Ct. App. 1975).

[66]          Ray v. Alad, 560 P.2d 3, 7 (Cal. 1977).

[67]          See also, Chaknova v. Wilbur-Ellis Co., 81 Cal. Rptr. 2d 871 (Ct. App. 1999).

[68]          See Henkel Corp. v. Hartford Accid. & Indem. Co., 62 P.3d 69 (Cal. 2003); Quemetco, Inc. v. Pacific Auto. Ins. Co, 29 Cal. Rptr. 2d 627 (Ct. App. 1994); General Accid. & Ins. Co. of Am. v. Superior Court, 64 Cal. Rptr. 2d 781 (Ct. App. 1997).

[69]          See Ruiz v. ExCello Corp., 653 P.2d 415 (Colo. Ct. App. 1982).

[70]          See Alcan Aluminum Corp. v. Electronic Metal Prods., Inc., 837 P.2d 282, 283 (Colo. Ct. App. 1992).

[71]          Johnston v. Amsted Indus., Inc., 830 P.2d 1141, 1144 (Colo. Ct. App. 1992).

[72]          See Parrish Chiropractic Ctr., P.C. v. Progressive Cas. Ins. Co., 874 P.2d 1049 (Colo. 1994).

[73]          Id. at 1053 (citations and emphasis omitted). (The court was addressing the transfer of a health insurance policy and decided that prohibitions against post-loss transfers of this type of policy were still enforceable).

[74]          Ricciardello v. J.W. Gant & Co., 717 F. Supp. 56, 58 (D. Conn. 1989).

[75]          Lynch v. Infinity Outdoor, Inc., 2003 WL 21213708 (Conn. Super. Ct. 2003).

[76]          See R.E.O., Inc. v. Travelers Cos., 1998 WL 285836 (Conn. Super. Ct. 1998).

[77]          See Elmer v. Tenneco Resins, Inc., 698 F. Supp. 535, 540 (D. Del. 1988).

[78]          Fehl v. S.W.C. Corp., 433 F. Supp. 939, 946 (D. Del. 1977).

[79]          See Tenneco Automotive, Inc. v. El Paso Corp., 2002 WL 453930 (Del. Ch. 2002).

[80]          Star Cellular Tel. Co. v. Baton Rouge CGSA, Inc., 1993 WL 294847, at *8 (Del. Ch. 1993), aff’d, 647 A.2d 382 (Del. 1994) (citations omitted).

[81]          See Graef v. Hegedus, 698 So. 2d 655 (Fla. Dist. Ct. App. 1997).

[82]          See Bernard v. Kee Mfg. Co., 409 So. 2d 1047, 1048-49 (Fla. 1982).

[83]          Lexington Ins. Co. v. Simkins Indus., Inc., 704 So. 2d 1384 (Fla. 1998).

[84]          See Better Constr., Inc. v. Nat’l Union Fire Ins. Co., 651 So. 2d 141, 142 (Fla. Dist. Ct. App. 1995).

[85]          See Bullington v. Union Tool Corp., 328 S.E.2d 726 (Ga. 1985).

[86]          See Farmex Inc. v. Wainwright, 501 S.E.2d 802, 804 (Ga. 1998).

[87]          See Ga. Code Ann. § 33-24-17 (2004).

[88]          See Santiago v. Safeway Ins. Co., 396 S.E.2d 506, 508 (Ga. Ct. App. 1990).

[89]          See Imperial Enters., Inc. v. Fireman’s Fund Ins. Co., 535 F.2d 287 (5th Cir. 1976).

[90]          Evanston Ins. Co. v. Luko, 783 P.2d 293, 295-96 (Haw. Ct. App. 1989); Man v. Raymark Indus., Inc., 728 F. Supp. 1461, 1469 (D. Haw. 1989).

[91]          See Tucker v. Paxson Mach. Co., 645 F.2d 620, 623 (8th Cir. 1981); Steel Co. v. Morgan Marshall Indus., Inc., 662 N.E.2d 595 (Ill. App. Ct. 1996).

[92]          See Vernon v. Schuster, 688 N.E.2d 1172, 1176 (Ill. 1997).

[93]          Gonzales v. Rock Wool Eng’g Co., 453 N.E.2d 792 (Ill. App. Ct. 1983); Myers v. Putzmeister, Inc., 596 N.E.2d 754, 758 (Ill. App. Ct. 1992).

[94]          See Knoll Pharm. Co. v. Auto. Ins. Co. of Hartford, 167 F. Supp. 2d 1004 (N.D. Ill. 2001).

[95]          See Winkler v. V.G. Reed & Sons, Inc., 638 N.E.2d 1228, 1233 (Ind. 1994).

[96]          See Miles Lamp Chimney Co. v. Erie Fire Ins. Co., 73 N.E. 107, 108-09 (Ind. 1905).

[97]          See Grand Labs., Inc. v. Midcon Labs., 32 F.3d 1277, 1283 (8th Cir. 1994).

[98]          Pancratz v. Monsanto Co., 547 N.W.2d 198, 201-02 (Iowa 1996).

[99]          DeLapp v. Xtraman, Inc., 417 N.W.2d 219, 221-22 (Iowa 1987).

[100]        See Comstock v. Great Lakes Distrib. Co., 496 P.2d 1308 (Kan. 1972).

[101]        See Stratton v. Garvey Int’l, Inc., 676 P.2d 1290, 1294 (Kan. 1984).

[102]        See Bolz v. State Farm Mut. Auto. Ins. Co., 52 P.3d 898, 903 (Kan. 2002).

[103]        See Am. Ry. Express Co. v. Commonwealth, 228 S.W. 433 (Ky. 1920).

[104]        See Bourque v. Lehmann Lathe, Inc., 476 So. 2d 1125, 1127 (La. Ct. App. 1985).

[105]        Dir. Bureau of Labor Standards v. Diamond Brands, Inc., 588 A.2d 734, 736 (Me. 1991).

[106]        See Jordan v. Hawker Dayton Corp., 62 F.3d 29, 32-33 (1st Cir. 1995).

[107]        See Nissen Corp. v. Miller, 594 A.2d 564, 565-66 (Md. 1991).

[108]        See id. at 567.

[109]        See Guzman v. MRM/Elgin, 567 N.E.2d 929 (Mass. 1991).

[110]        See Cargill, Inc. v. Beaver Coal & Oil Co., 676 N.E.2d 815, 819 (Mass. 1997).

[111]        SCA Disposal Servs. of New England, Inc. v. Central Nat’l Ins. Co., 1994 WL 879687 (Mass. Super. Ct. 1994).

[112]        See Foster v. Cone-Blanchard Mach. Co., 597 N.W.2d 506 (Mich. 1999).

[113]        See Turner v. Bituminous Cas. Co., 244 N.W.2d 873 (Mich. 1976).

[114]        See Pelc v. Bendix Mach. Tool Corp., 314 N.W.2d 614 (Mich. Ct. App. 1981).

[115]        2000 WL 33538535 (Mich. App. Ct. 2000).

[116]        318 F. Supp. 2d 530 (W.D. Mich. 2003).

[117]        See Gopher Oil Co. v. Am. Hardware Mut. Ins. Co., 588 N.W.2d 756, 763 (Minn. Ct. App. 1999).

[118]        See Closuit v. Mitby, 56 N.W.2d 428, 429 (Minn. 1953).

[119]        See id. at 764 (distinguishing Quemetco, Inc. v. Pacific Auto. Ins. Co., 24 Cal. App.4th 494 (1994)).

[120]        See Huff v. Shopsmith, Inc., 786 So. 2d 383, 388 (Miss. 2001).

[121]        See Brockman v. O’Neill, 565 S.W.2d 796, 798 (Mo. Ct. App. 1978).

[122]        See Young v. Fulton Iron Works Co., 709 S.W.2d 927 (Mo. Ct. App. 1986).

[123]        See Bowen v. W.R. Grace & Co., 781 F. Supp. 682, 683 (D. Mont. 1991).

[124]        See Jones v. Johnson Mach. & Press Co., 320 N.W.2d 481, 483 (Neb. 1982).

[125]        See id. at 484.

[126]        Paxton & Vierling Steel Co. v. Great Am. Ins. Co., 497 F. Supp. 573, 581 (D. Neb. 1980).

[127]        See, Hydro-Air Equip., Inc. v. Hyatt Corp., 852 F.2d 403 (9th Cir. 1988); Roll v. Tracor, Inc., 140 F. Supp. 2d 1073, 1082 (D. Nev. 2001).

[128]        See Washoe County Bd. of Sch. Trs. v. Pirhala, 435 P.2d 756, 759 (Nev. 1968).

[129]        See Simoneau v. South Bend Lathe, Inc., 543 A.2d 407 (N.H. 1988).

[130]        See Bielagus v. EMRE of N.H. Corp., 826 A.2d 559, 564 (N.H. 2003).

[131]        857 F. Supp. 140 (D.N.H. 1994).

[132]        See Ramirez v. Amsted Indus., Inc., 431 A.2d 811 (N.J. 1981). 

[133]        See Lefever v. K.P. Hovnanian Enters., Inc., 734 A.2d 290 (N.J. 1999).

[134]        Id.

[135]        See Federal Ins. Co. v. Purex Indus., Inc., 972 F. Supp. 872, 890 (D.N.J. 1997).

[136]        See Pankey v. Hot Springs Nat’l Bank, 119 P.2d 636, 640 (N.M. 1941).

[137]        See Garcia v. Coe Mfg. Co., 933 P.2d 243, 249 (N.M. 1997).

[138]        See Schumacher v. Richards Shear Co., 451 N.E.2d 195, 198 (N.Y. 1983).

[139]        Compare City of New York v. Charles Pfizer & Co., 688 N.Y.S.2d 23 (App. Div. 1999) (rejecting product line liability) with Hart v Bruno Mach. Corp., 679 N.Y.S.2d 740 (App. Div. 1998) (applying product line exception on the basis that New York courts are responsive to successor liability in strict products liability cases).

[140]        See EM Indus. Inc. v. Birmingham Fire Ins. Co., 529 N.Y.S.2d 121 (App. Div. 1988).

[141]        Id. at 123.

[142]        Id. at 122 (citation omitted).

[143]        1999 WL 777976 (S.D.N.Y. 1999) (citations omitted).

[144]        See Ardon Constr. Corp. v. Fireman’s Ins. Co., 185 N.Y.S.2d 723, 729 (Sup. Ct. 1959).

[145]        See Budd Tire Corp. v. Pierce Tire Co., 370 S.E.2d 267, 269 (N.C. 1988).

[146]        G.P. Publications, Inc. v. Quebecor Printing-St. Paul, Inc., 481 S.E.2d 674, 681-82 (N.C. Ct. App. 1997).

[147]        See Downtowner, Inc. v. Acrometal Prods., Inc., 347 N.W.2d 118, 121 (N.D. 1984).

[148]        See id. at 124-25.

[149]        See Flaugher v. Cone Automatic Mach. Co., 507 N.E.2d 331, 334 (Ohio 1987).

[150]        See id. at 337.

[151]        See McGaw v. South Bend Lathe, Inc., 598 N.E.2d 18, 21 (Ohio Ct. App. 1991); Hunt v. Waterbury Farrell Mfg. Ltd. P’ship, 1996 WL 697085 (Ohio Ct. App. 1996).

[152]        See Pulis v. U.S. Elec. Tool Co., 561 P.2d 68, 69 (Okla. 1977).

[153]        See Goucher v. Parmac, Inc., 694 P.2d 953, 954 (Okla. Ct. App. 1985).

[154]        See Erickson v. Grand Ronde Lumber Co., 92 P.2d 170 (Or. 1939).

[155]        See W. Helicopter Services, Inc. v. Rogerson Aircraft Corp., 728 F. Supp. 1506, 1511 (D. Or. 1990).

[156]        See In re Feiereisen, 56 B.R. 167, 169 (Bankr. D. Or. 1985).

[157]        See Childers v. Power Line Equip. Rentals, 681 A.2d 201, 212 (Pa. Super. Ct. 1996).

[158]        See Carpenter v. Federal Ins. Co., 637 A.2d 1008, 1012 (Pa. Super. Ct. 1994).

[159]        See Gen. Refractories Co. v. Travelers Ins. Co., 107 F.3d 7 (3d Cir. 1996) (reversing lower court without published opinion).

[160]        See Brunswick Corp. v. St. Paul Fire & Marine Ins. Co., 509 F. Supp. 750, 752-53 (E.D. Pa. 1981).

[161]        See Bunzl Pulp & Paper Sale, Inc. v. Golder, 1995 WL 89026 (E.D. Pa. 1995).

[162]        H.J. Baker & Bro., Inc. v. Orgonics, Inc., 554 A.2d 196, 205 (R.I. 1989) (citation omitted).

[163]        See Casey v. San-Lee Realty, Inc., 623 A.2d 16, 19 (R.I. 1993).

[164]        See H.J. Baker & Bro., 554 A.2d at 205.

[165]        See Pee Dee Nursing Home, Inc. v. S.C. Employment Sec. Div., 399 S.E.2d 777, 779 (S.C. 1990).

[166]        See Parker v. W. Dakota Insurers, Inc., 605 N.W.2d 181, 184 (S.D. 2000).

[167]        387 N.W.2d 515, 519-20 (S.D. 1986).

[168]        See Nat’l Am. Ins. Co. v. Jamison Agency, Inc., 501 F.2d 1125, 1128-29 (8th Cir. 1974).

[169]        See Mozingo v. Correct Mfg. Corp., 752 F.2d 168, 174 (5th Cir. 1985).

[170]        See Griggs v. Capital Mach. Works, Inc., 690 S.W.2d 287, 292 (Tex. Ct. App. 1985).

[171]        See Marcis & Assoc., Inc. v. Neways, Inc., 60 P.3d 1176, 1180 (Utah Ct. App. 2002).

[172]        See Ostrowski v. Hydra-Tool Corp., 479 A.2d 126, 127 (Vt. 1984).

[173]        See id.

[174]        See People’s Nat’l Bank of Rocky Mount. v. Morris, 148 S.E. 828, 829 (Va. 1929).

[175]        See Harris v. T.I., Inc., 413 S.E.2d 605, 609-10 (Va. 1992).

[176]        See Hall v. Armstrong Cork, Inc., 692 P.2d 787 (Wash. 1984).

[177]        See George v. Parke-Davis, 733 P.2d 507, 510 (Wash. 1987).

[178]        See N. Ins. Co. v. Allied Mut. Ins. Co., 955 F.2d 1353, 1357-58 (9th Cir. 1992); B.S.B. Diversified Co., Inc. v. Am. Motorists Ins. Co., 947 F. Supp. 1476, 1481 (W.D. Wash. 1996).

[179]        See B.S.B. Diversified, 947 F. Supp. at 1480.

[180]        See Unigard Ins. Co. v. Leven, 983 P.2d 1155, 1164 (Wash. Ct. App. 1999).

[181]        See Davis v. Celotex Corp., 420 S.E.2d 557 (W. Va. 1992).

[182]        See Fish v. Amsted Indus., Inc., 376 N.W.2d 820 (Wis. 1985).

[183]        607 N.W.2d 294, 299 (Wis. Ct. App. 2000).

 

(Authors’ bios)

 

Diane L. Polscer is a partner in the firm Gordon & Polscer, LLC in Portland, Oregon.  Her practice is dedicated to insurance coverage and defense and complex commercial litigation.  Ms Polscer is past chair of DRI’s Excess & Reinsurance Subcommittee.  She is a faculty member of the National Institute for Trial Advocacy, an organization for the professional training of lawyers in trial advocacy skills.  Ms. Polscer is a member of the Federation of Defense & Corporate Counsel.

 

Thomas A. Gordon is a partner in the firm Gordon & Polscer, LLC in Portland, Oregon.  His practice is dedicated to insurance coverage litigation, insurance defense litigation, complex commercial law, and technological torts.  Mr. Gordon has served on DRI’s Board of Directors, chaired DRI’s Insurance Law Committee and served on its Law Institute Committee.  He is also a member of I.A.D.C.