Whither Rhode Island?: "Manicestation" and Contribution Claims

Rhode Island has the distinction of being not only the smallest state in the union but also one of the few that still adhere to the principle of “manifestation” in resolving long-tail insurance coverage disputes. Both “manifestation” and “all sums” are similar in that the insured’s rights are initially limited to a single year of coverage. They differ dramatically, in that the “all sums” approach recognizes that bodily injury or property damage may have occurred over a period of years and allows the targeted insurer to seek contribution from insurers in other years where injury occurred (although generally not from the insured for uninsured or self-insured periods.) By contrast, the “manifestation” approach assumes that bodily injury or property damage has only occurred in the particular year where it was discovered or, as Rhode Island courts have ruled, when it was discoverable through the exercise of reasonable diligence. See CPC Int., Inc. v. Northbrook Excess & Surplus Ins. Co., 668 A.2d 647 (R.I. 1995) and Textron-Gastonia, Inc. v. Aetna Cas. & Sur. Co., 723 A.2d 1138 (R.I. 1999).

In light of this analysis, may a triggered insurer in Rhode Island ever seek contribution from other carriers? Such was the issue presented to the Rhode Island Supreme Court in its recent opinion in Employers Mut. Cas. of Wausau v. Arbella Protection Ins. Co., No. 2009-330 (R.I. July 12, 2011). At issue was the claim of a neighboring property owner that Viking Stone had allowed contaminated water from its rock quarry to spill onto his land over a period of years, killing trees and other vegetation and damaging the home’s foundation.


 

The case was defended by the quarry operator’s current insurer (Employers). Employers commenced an action for contribution against Viking Stone’s earlier insurer, Arbella. Employers initially only sought contribution from Arbella, arguing that because the quarry operations were alleged to have commenced during Arbella’s policy period its coverage was triggered. In a later filing, however, Employers argued in an amended complaint that because this “occurrence” started during the Arbella policy, Employers was relieved of any duty to defend or indemnify Viking Stone.

The Superior Court agreed.  On appeal, however, the Rhode Island Supreme Court found disputed issues of fact as to the “trigger” date. In particular, the Supreme Court pointed to interrogatory answers in which the plaintiff contended that the first flooding of his property occurred sometime in 2002 or 2003. Arbella had argued that there was no proof that the flooding was a single incident. Further, Arbella noted that there were questions of fact with respect to whether the property damage had taken place at all during the period of its coverage. Under the circumstances, the Rhode Island Supreme Court agreed with Arbella that there was conflicting evidence with respect to whether the flooding at the plaintiff’s house was caused by the insured and, if so, whether the flooding constituted one or multiple “occurrences.” There was, for instance, evidence that the water in the plaintiff’s home could be coming from underneath the property rather than flowing onto the property from the insured’s property.

The Supreme Court declined to find that the flooding incidents had involved “continuous or repeated exposure to substantially the same general harmful conditions” such that they could be treated as arising out of a single occurrence. The court’s analysis hinges on a subtle linguistic distinction between “continuous” and “continual events.

The court noted that dictionaries define “continuous” events as being “uninterrupted in time, sequence, substance or extent,” whereas events that occur “continually” take place recur “regularly or frequently.” In this case, the court observed that the flooding events might well have been “continual” as involving multiple discreet occurrences but were not the result of one “continuous” occurrence.

The Employers opinion is interesting in several respects. First and foremost, the word “manifestation” appears nowhere in the court’s opinion. One may only wonder whether the Supreme Court is aiming to distance itself from its earlier opinions or simply did not feel the need to address the issue since the flooding and contamination problems at issue were not truly latent or long-tail injuries.

Nor did the Court altogether reject Employers’ arguments. Indeed, it would seem that Employers might have prevailed had there been clear evidence that there had been continuous flooding that had commenced prior to the issuance of the first Employers policy in 2004.

A further mystery is why no mention was made of the typical anti-Montrose wordings that have been featured in CGL policies for the last decade precluding coverage for the resumption or continuation of property damage that has begun prior to the policy. It may be that, like some policies, the Employers’ wordings required notice to the insured that may have been lacking here. Alternatively, Employers may simply not have raised the issue or may not have had such wordings in its policies. In any event, the inclusion of such wordings would likely have addressed the problems that confounded the Supreme Court in Employers.

No Contribution For Defense Of Additional Insured

The duty to defend, in the context of a contribution lawsuit between insurers, and the right to pursue appeal after an unfavorable summary adjudication ruling, were the subjects of a decision from California’s Court of Appeal, Second Appellate District (Los Angeles).

In Monticello Insurance Company v. Essex Insurance Company (2008) __ Cal.App.4th __ (2008 WL 1851316), the court of appeal affirmed the trial court’s ruling that Monticello failed to prove on motion for summary adjudication/judgment that Essex had a duty to contribute to the defense of a general contractor (“GC”) in a construction defect case.  Monticello was the direct insurer of the GC and Essex insured the GC as an additional insured under a policy issued to a drywall subcontractor. While the legal principles of equitable contribution may not be new, the case is an example of what evidence was found to be inadequate to substantiate the right to contribution. Both the trial and appellate courts (even though reviewing by different standards) found Monticello failed to show there was a potential that the drywaller’s work caused damage to other property.

(What the court does not address, and perhaps Monticello did not feature, was that Essex must have concluded there was a potential for coverage as it was defending its direct insured, the drywaller.)

 

The case suggests the insurer seeking contribution should consider: (1) continuing to provide additional information to the other insurer, which information may impact a decision on the duty to defend, and (2) filing an earlier declaratory relief action (while the defense is ongoing).

The court also addressed whether the parties had standing to appeal. The appeal followed a ruling on summary judgment/adjudication. There were still issues that could have been litigated further, but it did not make much sense to litigate in light of the court’s ruling. Therefore, the parties stipulated judgment would be entered against Monticello for purposes of concluding the case so Monticello could immediately appeal. The court found this appropriate under the circumstances.

Frustration Mounts in Texas as Primary Carriers Struggle with How to Deal with Recalcitrant Co-Primary Carriers

A Federal District Court Judge from the Southern District of Texas’ Galveston Division recently granted summary judgment against an insurer seeking to enforce identical pro rata sharing provisions contained in multiple primary insurance policies.  In doing so, the court highlighted the lack of options primary carriers now face in Texas when co-primary carriers don't contribute to defense or indemnity benefits to the common insured.  In Nautilus Ins. Co. v. Pacific Employers Ins. Co., No. G-04-619 (S.D. Tex.  February 25, 2008), several insurers were called on to defend and indemnify a seismic testing company which allegedly damaged over 200 buildings in Galveston County while conducting seismic testing.  All of the insurers except Pacific Employers contributed to the settlement and Nautilus Insurance then sought to recover the amounts it overpaid to fund the settlement from Pacific by way of subrogation and enforcement of the policies respective pro rata "other insurance" sharing provisions.  The suit among the co-primary carriers resulted in summary judgment motions being filed on the issue of whether a settling co-primary carrier in Texas can sue a recalcitrant co-primary carrier for not paying it's fair share of the defense costs or the settlement.  Relying on the Texas Supreme Court’s recent decision in Mid-Continent Insurance Co. v. Liberty Mutual Insurance Co., 236 S.W.3d 756 (Tex. 2007), the District Court held last week that because the insured had been fully indemnified, the settling insurer had no claim under Texas law against the non-settling insurer because “there is nothing to which Plaintiff can be subrogated.”  This harsh result is the inevitable consequence of the Texas Supreme Court's decision from February in Mid-Continent v. Liberty Mutual

Because of the proliferation of suits involving construction defects, intellectual property violations, toxic torts, premise liability and other significant torts, it is now extremely common for insured defendants to have two or more primary liability carriers whom they turn to for defense and indemnity benefits.  The unwillingness of the Texas Supreme Court to allow one carrier to sue another for reimbursement, contribution or subrogation puts Texas in an extreme minority on this issue and forces carriers in that state to become very creative when settling liability suits when one or more other primary carriers have not or will not contribute to defense or settlement costs.  Carriers in such a situation must consider formal assignments from insureds and other creative alternatives before allowing the underlying liability to be settled and dismissed.   Otherwise, they will find themselves in the same position as Nautilus having overpaid a claim they did not fully owe with no avenues for reimbursement against the carrier who refused to pay timely.