The Next Big Thing: "Montrose" Clauses and CD Disputes

In the wake of the California Supreme Court's Montrose opinion, ISO promulgated various new clauses purporting to cut off coverage for continuing losses.  Thus, current CGL forms contain language in the insuring agreement precluding coverage for losses that are already known to the insured.  Additionally, some policies now endorsements excluding coverage for the continuation of property damage that first occurred prior to the policy.

Despite the significance of these "Montrose" clauses for construction defect litigation, there has been little or no case law construing their scope and effect until recently.

Shaun Baldwin posted last month concerning a new Indiana opinion that construed a “Montrose” clause in a CGL policy to extend an insurer’s coverage beyond the policy’s expiration. In Grange Mut. Cas. Co. v. West Bend Mut. Ins. Co., No. 29A02-1008-PL 965 (Ind. App. March 15, 2011), the Indiana Court of Appeals had ruled that the insurer whose policy was in effect when the insurer had installed the storm drain pipes must also covered damaged caused by later leakage due to language in its policy extending coverage to “any continuation, change or resumption of that property damage after the end of the policy period.”

Whereas Grange Mutual analyzed the effect of such provisions in extending coverage, a new Fifth Circuit opinion considered the extent to which “Montrose” clauses might serve as a tool for later insurers to bar coverage for known losses. In Maryland Cas. Co. v. Acceptance Indemnity Ins. Co., No. 10-50283 (5th Cir. April 25, 2011), the U.S. Court of Appeals for the Fifth Circuit ruled that a later CGL carrier could not raise “Montrose” wordings as a bar to claims for equitable subrogation brought by the insurer that was on the risk when water intrusion problems first commenced.

Olympic Pools had been hired by a homeowner in 2002 to build a “negative edge” swimming pool in his backyard in Texas. The pool underwent several repairs over the next few years as four leaks and a large crack developed. In April 2003, just after the pool had been completed and filled with water for the first time, there was a leak under the northeast flower bad planter that the insured repaired. Two years later, however, a second and third leak occurred in the pump equipment area and another under the pool shell near the main drain. The leak under the pool shell caused the pool level to drop two feet in a day, eventually draining the pool within two days. After the pool had drained, the plaintiff’s property manager noticed a long crack running the length of the negative edge wall across the basin. A different company was hired to fix the leak under the shell and to chisel, epoxy and re-plaster the cracked area. The fourth leak occurred in late 2005, after which the customer hired an engineer to analyze the pool structure and filed suit against Olympic Pools.

Olympic Pools tendered the defense of the suit to Maryland Casualty and Acceptance Indemnity that had respectively insured it between 2002 and 2006. Maryland agreed to accept the defense of the case under its 2002-2003 policy but Acceptance, which had been on the risk from August 2003 until 2006, disclaimed any obligation to defend, citing the anti-Montrose wordings in its policy. After Maryland Casualty paid $590,000 to settle the lawsuit, it sued Acceptance under theories of contribution, contractual subrogation and equitable subrogation.

In the ensuing coverage litigation, a federal district court in Texas ruled that Acceptance did have a duty to defend and must therefore reimburse Maryland Casualty for a pro rata share of the costs of defense. While holding that there is no right of equitable contribution among successive insurers in light of the Texas Supreme Court’s opinion in Mid-Continent Ins. Co. v. Liberty Mutual Ins. Co., 236 S.W.3d 765 (Tex. 2007), the court allowed the surviving subrogation claim to proceed to trial, where a jury concluded that 75% of the insured’s damages were attributable to property damage that first occurred during one of Acceptance’s policy periods.

On appeal, the U.S. Court of Appeals for the Fifth Circuit agreed with the District Court that Mid-Continent did not preclude an insurer’s right of subrogation against another carrier, even where the insured itself had been fully indemnified. Further, the Court of Appeals declined to hold that there was insufficient evidence to support the jury’s verdict on when property damage “first occurred.” The Fifth Circuit found that in this case the swimming pool problems for which the insured had been sued had resulted from two different causes, the second of which had resulted during Acceptance’s policy period. Accordingly, even if the underlying cause of the problem had resulted from negligent work by the insured contractor during Maryland Casualty’s policy, the Fifth Circuit held that the property damage occurring during Acceptance’s policy was covered since it had resulted from a different cause than that which had occurred during Maryland’s policy.

These cases illustrate a trend that we are likely to see more of in the future, where damages are dissected into separate “occurrences” so as to trigger additional policies and avoid issues with respect to common law “known loss” as well as “Montrose” language of the sort discussed here.

To Stay or Not to Stay

When an insurer contemplates the pros and cons of filing a declaratory relief action to determine a coverage issue, one important factor is whether the action is likely to be stayed until conclusion of the underlying dispute against the insured.  In California, coverage actions are stayed to avoid having facts that impact both coverage and the insured’s liability in the underlying action decided (or even the subject of discovery) in the coverage lawsuit if this would prejudice the insured’s defense of the underlying lawsuit. See Haskel, Inc. v. Sup. Ct. (1995) 33 Cal.App.4th 963, 980; Montrose Chem. Corp. v. Sup. Ct. (1993) 6 Cal.4th 287, 302.

In Great American v. Sup. Ct. (Angeles Chem. Co.) ___ Cal.App.4th __ (2009 WL 3234636), California’s appellate court  (Second District – Los Angeles/Crosky) reviewed the issue of overlapping facts.  However, after doing so (and finding the coverage action could proceed because it raised contract interpretation issues and not factual issues pertinent to the underlying lawsuit), the court still remanded the case to the trial court to “balance the possible prejudice to the parties by the grant or denial of the insured’s motion to stay.”  This may pose a nearly impossible situation for an insurer if no other insurer is defending the lawsuit.  However, CGIS Insurance Services, Inc. v. Sup. Ct. (2008) 168 Cal.App.4th 1493 (also written by Justice Crosky) should also be considered, in which the court found a stay inappropriate where the question presented was a strictly legal issue.
 

Great American’s coverage lawsuit arose out of an underlying environmental pollution case.  Great American and several other insurers agreed to defend the insureds.  Great American filed its declaratory relief action for a determination that its policy limits were exhausted and therefore there was no further duty to defend.  The legal issues presented by this claim were two fold: (1) whether there was only $500,000 per occurrence available in applicable limits; and (2) whether there was an additional annual limit available because the insured had paid for an additional couple of months of coverage.  The insured argued the policy limits question necessitated determination of facts in the underlying case, including whether there was more than one occurrence and what caused the pollution.  The insured also argued it might assert a bad faith claim which would create factual issues that should be stayed.

The appellate court made short shrift of these arguments.  The possible bad faith claim was speculative.  No proposed claim had been presented to the court and, therefore, none could be considered.  On the issue of the amount of policy limits available, the court concluded these were contract interpretation issues that did not require discovery of or determination of the facts in the underlying case.  So a stay was not appropriate on those grounds.

However, the appellate court held another factor had to be considered - the prejudice of the insured being compelled to fight a “two-front war.”  The court indicated this factor must be considered “every time an insured seeks to stay a declaratory relief action while the underlying action is still pending.”  Thus, the trial court was instructed to balance the insured’s interests in not fighting a two-front war against the insurer’s interest in not being required to continue to pay for the defense where it may not owe a defense and may not be able to recoup that money.  The appellate court noted this issue is “circumstance-specific” and suggested it could depend on factors such as:

• the anticipated duration of the underlying litigation,
• whether the insured has separate counsel in the two actions, and
• availability of other insurance to cover the costs of defense.

Certainly the appellate court’s consideration of the relative burdens/prejudice is based in part on that, in California, an insurer has a right to reimbursement from the insured and contribution from other insurers if the insurer defends or indemnifies and later is found to have had no obligation to defend or indemnify.  See Buss v. Sup. Ct.(1997) 16 Cal.4th 35, 48-49.

The appellate court directed the trial court, on remand, to balance “the prejudice to the insureds if they are required to litigate both cases at once against the prejudice that Great American will sustain if it is forced to continue to provide a defense until the underlying action is resolved.”  What may help Great American in this particular case is that there are other solvent insurers defending.  This certainly is not always the case.  The court also indicated the trial court should consider alternative methods to achieve a fair balance of the interests of insurer and insured – suggesting there may be legal issues that could be determined on demurrer or motion for summary judgment at no great expense to either party.