September 2015
Volume 6
Issue 9
COMMERCIAL
GENERAL
LIABILITY
D I S PAT C H
MEET OUR EDITORS
JOANNA L. CROSBY, Partner
New Jersey Office | jcrosby@tresslerllp.com
TOP STORIES
>> CALIFORNIA SUPREME COURT OVERRULES HENKEL, FINDING
CONSENT-TO-ASSIGNMENT CLAUSES ARE UNENFORCEABLE FOR
POSTLOSS ASSIGNMENT OF INSURANCE COVERAGE RIGHTS
By: Elizabeth Musser, Partner in the Los Angeles Office............................................. P2
LINDA TAI HOSHIDE, Partner
Los Angeles Office | lhoshide@tresslerllp.com
>> THE 10TH CIRCUIT DEMONSTRATES THAT LIMITING OR EXCLUDING
L ANGUAGE CAN BE A POWERFUL TOOL TO INSURERS
By: Si-Yong Yi, Associate in the Chicago Office........................................................... P3
>> CALIFORNIA COURT MAKES AN END RUN AROUND ASBESTOS AND TOTAL
POLLUTION EXCLUSIONS TO FIND DUTY TO DEFEND
By: Mary McPherson, Partner in the Orange County Office....................................... P4
>> CALIFORNIA SUPREME COURT FINDS CUMIS COUNSEL DIRECTLY
LIABLE IN LIMITED CIRCUMSTANCES FOR UNNECESSARY AND
UNREASONABLE FEES
By: Kate Tammaro, Partner in the New Jersey Office.................................................. P7
JAMES A. PINDERSKI, Partner
Chicago Office | jpinderski@tresslerllp.com
CONTRIBUTING EDITORS
REGISTRATION NOW OPEN!.................................................................................... P5
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California Supreme Court Overrules Henkel,
Finding Consent-to-Assignment Clauses are
Unenforceable for Postloss Assignment of
Insurance Coverage Rights
The California Supreme Court overruled its decision in Henkel Corp v. Hartford Accident & Indemnity Co., 29 Cal. 4th
934 (2003), applying a rarely-cited statute to find that consent-to-assignment clauses are unenforceable for postloss
assignments of insurance coverage rights. Fluor Corp. v. Super. Ct., 61 Cal. 4th 1175 (Aug. 20, 2015).
Elizabeth Musser
Partner in the
Los Angeles Office
Hartford Accident & Indemnity Co. provided general liability
coverage to Fluor Corporation – a company providing
engineering, procurement and construction (EPC) services –
under 11 policies from 1971 to 1986. Each of the Hartford
policies contains a consent-to-assignment clause, which
states, “Assignment of interest under this policy shall not
bind the Company until its consent is endorsed hereon.”
Beginning in the 1980s, Fluor was named as a defendant
in many asbestos-related lawsuits, for which Hartford and
other carriers provided coverage. Also in the 1980s, Fluor
acquired mining business A.T. Massey Coal Company as a
subsidiary. In September 2000, in a corporate restructuring
known as a “reverse spinoff,” Fluor created a subsidiary called
“Fluor Corporation” (New Fluor), and changed the name
of the original Fluor to “Massey Energy Company.” Fluor
transferred all EPC assets and liabilities to New Fluor (the
parties dispute whether the transfer of assets and liabilities
included Fluor’s insurance policies, but the Court does not
address that issue in its opinion). New Fluor advised Hartford
of the reverse spinoff in May 2001. Hartford continued to
defend New Fluor in asbestos-related lawsuits.
In a coverage action in 2009, Hartford asserted in a crosscomplaint that Fluor failed to comply with the consent-toassignment clauses in its policies in transferring assets to
New Fluor. Hartford relied on the California Supreme Court’s
decision in Henkel Corp v. Hartford Accident & Indemnity Co.,
29 Cal. 4th 934 (2003). In Henkel, the California Supreme
Court enforced a consent-to-assignment clause postloss,
finding that the clause was enforceable if the attempted
assignment was made before the underlying claims were
reduced to a judgment for a sum of money due.
New Fluor argued that application of Hartford’s consent-toassignment clause was barred by California Insurance Code
section 520, which provides, “An agreement not to transfer
the claim of the insured against the insurer after a loss has
happened, is void if made before the loss ….” The Court in
Henkel did not consider section 520, which was originally
enacted as a civil statute in 1872 (when liability insurance
did not exist), was transferred to the California Insurance
Code in 1935, amended in 1947, and has very rarely been
invoked in recent decades. It appears that neither the
insured’s nor the insurer’s counsel raised section 520 in the
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briefing or argument in Henkel, and that none of the amicus
curiae briefs addressed the statute.
The California Court of Appeal applied Henkel to determine
that Hartford could rely on its consent-to-assignment clause,
so that any assignment of rights under its policies before any
claims were reduced to a judgment was void. The Court of
Appeal addressed New Fluor’s argument about the potential
applicability of section 520, and found that the statute
applies only to first-party insurance, not to third-party
liability insurance.
The California Supreme Court reversed, overruling Henkel to
the extent Henkel stands for the proposition that consent-toassignment clauses apply to any attempted assignment prior
to judgment or settlement. The California Supreme Court
first held that section 520 applies to third-party liability
insurance, holding that nothing in the text of the statute
limits its application to first-party insurance. Indeed, the
legislature specifically transferred section 520 to California’s
Insurance Code in 1935 (when liability insurance was fully
available), and the legislature amended section 520 in 1947
(when liability insurance was even more common) to exempt
life and disability insurance. According to the Court, these
factors indicated that there is no reason to limit the statute
to first-party insurance.
Next, the Court addressed the meaning of the phrase “after
a loss has happened” in the statute. The Court considered
whether it refers to the occurrence of bodily injury or property
damage, as urged by New Fluor, or whether it refers to judgment
or settlement for a sum of money, as urged by Hartford. As part
of its evaluation of the meaning of “after a loss has happened,”
the Court engaged in a detailed analysis of nineteenth century
legislative history for section 520 and a similar statute enacted
in New York, and reviewed a series of early liability insurance
coverage cases in California and nationwide.
As a result of this analysis, the Court determined that early
liability insurance cases held that an insured may assign its
postloss insurance coverage rights, with or without the consent
of the insurer. The idea driving these early liability decisions
is that the insured loss happens at the time of injury during
the policy period, so there is no need to continue to protect
the insurer after the policy period, when the loss has already
Continued from Page 1
occurred. (The Court noted that the purpose of consent-toassignment clauses is to protect the insurer from needing to
provide coverage for losses it has not bargained to cover.)
The Court opined that given the strong preference in the
decisional law to allow assignment of postloss insurance
coverage rights, Henkel is the anomaly. In light of the
legislative history, survey of decisional law, and section 520,
the California Supreme Court found that Hartford’s consentto-assignment clauses do not apply to assignment of postloss
insurance coverage rights, thereby overruling Henkel.
Tressler Comments
This important case from California’s highest state court substantially changes California coverage law regarding consentto-assignment clauses, as discussed above. It demonstrates the enormous impact that a statute can have on decisional
law, and the difficult burden in overcoming a statute that is apparently contrary to decisional law.
In Frontier Oil Corp. v. RLI Insurance Co., 153 Cal. App. 4th 1436 (2007), a California Court of Appeal relied on California
Civil Code section 1646 – also enacted in 1872 – to provide a seminal case on California’s choice of law principles. The
Fluor decision is also notable for the California Supreme Court’s expansive discussion of legislative history and case law
– only hinted at above – in which the Court tries to grapple with the development of liability insurance and attendant
assignment rights. In any case involving the applicability of a statute, and particularly an older statute, litigants should
research the legislative and decisional law history, and provide the court with an explanation as to the applicability (or
inapplicability) of the statute at issue.
The 10th Circuit Demonstrates that Limiting
or Excluding Language Can Be a Powerful
Tool to Insurers
Si-Yong Yi
Associate in the
Chicago Office
(No picture available)
In Nationwide Mut. Ins. Co. v. Prater, 2015 WL 4665792 (10th Cir. 2015), the 10th U.S. Circuit Court of Appeals
affirmed the District Court’s finding that an insurance policy did not cover the claims that were excluded by the
limiting provisions of the policy.
Plaintiffs Wayne and Tonya Prater accompanied their
children to a birthday party held at Kingdom Fitness & Fun,
Inc. (Kingdom), a gymnastics facility. While at the party,
Wayne Prater jumped from a platform into a foam pit,
breaking his back and becoming paralyzed from the waist
down. The Praters then filed suit against Kingdom, the
individual owners of Kingdom, and the owner of the building
and property where Kingdom operated.
The insurance policy that Kingdom purchased from
Nationwide Mutual Insurance Company (Nationwide) was
sold as “gymnastics and cheerleading insurance,” and the
insurance application form required Kingdom to identify the
specific gymnastics-related activities it engages in and to
report the total number of birthday or social parties it may
hold at its facility on an annual basis. However, Kingdom did
not indicate that it held birthday or social parties nor did it
list the number of parties it hosted. Also, the “Exclusion –
Designated Operations” section stated that the policy did not
apply to the operations described in the Exclusion Schedule,
which described Kingdom’s operations “as a sports complex
or multi-purpose facility, except for those sport(s) and/or
subsidiary activities you have reported, paid for, and that
have been approved by the program administrator.”
Nationwide filed a declaratory judgment action arguing that
it had no duty to defend or to indemnify Kingdom because
its policy did not cover birthday parties, and Prater’s injuries
occurred during a birthday party.
In its analysis, the 10th Circuit first considered whether the
general coverage provisions of the policy covered Prater’s
injuries. The policy stated Nationwide would pay those
sums that the insured becomes legally obligated to pay as
damages because of bodily injury “to which this insurance
applies.” Because of this language, the 10th Circuit needed to
examine other sections of the policy to determine whether
Prater’s injury would be covered.
The “Limitation of Coverage to Designated Premises, Activities
or Operations” section of the policy stated, “If reported,
approved and the applicable premium has been paid, covered
operations include birthday/social party[s]...” The 10th Circuit
found that because Kingdom did not report, obtain approval,
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Continued from Page 3
or pay additional premium for birthday coverage, injuries
occurring at birthday parties were not covered.
In addition, the 10th Circuit rejected Prater’s contention
that even if his injury was not covered under the general
provisions of the policy, his injury was covered because of two
endorsements: the Legal Liability to Participants endorsement
and Professional Liability Coverage endorsement. The Legal
Liability to Participants endorsement added coverage for
bodily injury to a “Participant,” but this endorsement did not
add coverage for Prater’s injury because the endorsement
specifically excluded coverage for damages “to which this
insurance does not apply.” Similarly, the Professional Liability
Coverage endorsement also included a phrase excluding
coverage for damages for wrongful acts “to which this
insurance does not apply.”
Further, the 10th Circuit found that even if the policy’s
coverage provisions covered birthday parties not reported
to or approved by Nationwide, the Exclusion provision of
the policy would exclude coverage, as the birthday parties
were part of Kingdom’s operations but were not reported or
approved by Nationwide and paid for with separate premium.
Tressler Comments
This case illustrates how well written limitation/exclusion sections of a policy can effectively limit the scope of insurance
coverage. Policy premiums and intent of the scope of coverage should be considered when reviewing coverage. The ExclusionDesignated Operations provisions deserve careful examination.
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California Court Makes an End Run Around
Asbestos and Total Pollution Exclusions to Find
Duty to Defend
Mary McPherson
Partner in the
Orange County Office
A federal District Court in San Francisco has ruled that an insurer had a duty to defend an apartment building owner and
its general contractor in a suit brought by tenants who were allegedly exposed to asbestos during a construction project.
Although the policy contained broad Asbestos and Total Pollution exclusions, the court found that the underlying
allegations, i.e. wrongful entry into the tenants’ unit by the insureds and “constructive eviction” due to “dust, debris
and unknown contaminants” in their units during an asbestos abatement project, included potentially covered claims,
which fell outside these exclusions. Therefore, the insurer was obligated to defend both the building owner (its named
insured) and the general contractor (additional insured) against the lawsuit. Parklyn Bay Co., LLC v. Liberty Insurance
Corp., No. C-13-3124 EMC, 2015 WL 4760376 N.D. Cal., (August 12, 2015) (unpublished).
In 2012, two tenants of an apartment building sued the
building’s owner, Parklyn Bay Co., LLC (Building Owner), and
its general contractor, Oliver and Co. (GC), alleging they had
knowingly or negligently exposed the tenants to asbestos
during a construction project undertaken to abate asbestos
contained in the buildings (Lawsuit). The Lawsuit also alleged
that when the tenants were out of their unit, “defendants
and/or workers employed by defendants made multiple
entries into the Premises without prior notice, and without
the consent of plaintiffs.” The tenants further claimed that
when “defendants began demotion of the unit directly above
plaintiffs’ unit [it caused] large quantities of dust, debris, and
unknown contaminants to enter into plaintiffs’ unit.”
The Building Owner and GC both tendered their defense
of the Lawsuit to the Building Owner’s commercial general
liability insurer, Liberty Surplus Insurance Corp. (Liberty).
Liberty denied coverage on the ground that the Lawsuit fell
within the policy’s Asbestos and/or Total Pollution Exclusions.
The Building Owner eventually settled the Lawsuit on behalf
of itself and the GC, taking assignment of the GC’s coverage
and bad faith claims against Liberty.
Liberty’s policy definition of “personal and advertising
injury,” included an offense of … (c) The wrongful eviction
from, wrongful entry into, or invasion of the right of
private occupancy or a room, dwelling or premises that a
person occupies, committed by or on behalf of its owner,
landlord or lessor[.] The policy’s Asbestos Exclusion barred
coverage for “‘personal and advertising injury’ arising out
of or related in any way, either directly or indirectly, to: (a)
asbestos, asbestos products, asbestos-containing materials
or products, asbestos fibers or asbestos dust, including, but
not limited to, manufacture, mining, use, sale, installation,
removal or distribution activities; (b) exposure to, testing
for, monitoring of, cleaning up, removing, containing or
treating asbestos, asbestos products, asbestos-containing
materials or products, asbestos fibers or asbestos dust;
and (c) any obligation to investigate, settle or defend, or
indemnify any person against any claim or suit arising
out of, or related in any way, either directly or indirectly,
to asbestos products, asbestos-containing materials or
products, asbestos fibers or asbestos dust. The policy also
contained a Total Pollution Exclusion.
The Building Owner and GC argued there was a duty to defend
because, in addition to and separate from, the asbestos
claims, plaintiffs’ claims were for unlawful entries into their
units unrelated to the alleged exposure to asbestos: “During
the time that plaintiffs were out of their unit, defendants
and/or workers employed by defendants made multiple
entries into the Premises without prior notice, and without
consent of plaintiffs” (Paragraph 18).
Liberty argued that, even though Paragraph 18
made no specific reference to asbestos, the asbestos
exclusion applied because the reason Parklyn Bay and
its employees allegedly made multiple entries into the
apartment without notice or consent was “to abate the
asbestos.” The court agreed with the Building Owner
and GC, finding there was no allegation anywhere in the
underlying complaint stating that the Building Owner or
its GC repeatedly entered the tenants’ apartment without
permission in order to abate asbestos. In the court’s view,
the allegations of Paragraph 18 raised at least the potential
for coverage under the “personal and advertising injury”
provision, which expressly covered injuries “arising out
of … [the] wrongful entry into, or invasion of the right of
private occupancy or a room.”
While recognizing Liberty could consider extrinsic
evidence in determining the duty to defend, the court
rejected Liberty’s argument that the Building Owner had
“admitted” in its cross-complaint that the wrongful entries
were related to asbestos removal. First, the court held the
allegations in the Building Owner’s cross-complaint against
GC that Liberty claimed were “admissions” were not, in
fact, admissions. Second, Liberty failed to establish that
it had knowledge of this alleged “admission” at the time
it received the tenders from the Building Owner and GC.
Thus, a cause of action for wrongful entry could lie even in
the absence of asbestos.
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Continued from Page 5
The court also found that the tenants’ allegations that
they were forced to “flee” their apartment at least in part
because of the “dust, debris, and unknown contaminants”
provided an additional, independent basis for a duty to
defend. As this allegation did not specifically state that the
contaminants contained asbestos, and this fact was not
established beyond dispute, the court found the Asbestos
Exclusion did not apply to preclude a duty to defend. The
court also found that Liberty failed to show that the “dust
and debris” and “unknown contaminants” would necessarily
fall within the policy’s Total Pollution Exclusion, citing to
California decisions differentiating between “conventional
environmental pollution” and “ordinary dust.”
In reaching the conclusion that Liberty had a duty to defend,
the court repeatedly focused on what the insurer knew and
when it knew it, applying the general rule that a duty to
defend depends on allegations and facts known at the time
of tender.
Tressler Comments
Although the court’s ruling is questionable in light of what appears to be evidence that the construction activity were all for
the purpose of abating asbestos, and the policy had a broad all encompassing asbestos exclusion, this unpublished decision
reminds insurers that courts will go out of their way to find a duty to defend. Thus, it is important to consider whether any
of the allegations could fall outside exclusions such as in this case, where the court found that an allegation of a wrongful
entry, not specifically alleged to be related to the asbestos abatement activities, and/or allegations of wrongful eviction due
to “dust and debris,” can be found to raise a possibility of coverage. This decision also reminds insurers that it is important
to investigate as soon as the tender is received, as the court questioned whether the insurer knew, at the time it denied
coverage, that all of the claims allegedly arose out of asbestos related activities or if it only determined that that was the only
source of claims later in the litigation and not at the time the Lawsuit was originally tendered.
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California Supreme Court Finds Cumis Counsel
Directly Liable in Limited Circumstances for
Unnecessary and Unreasonable Fees
Kate Tammaro
Partner in the
New Jersey Office
In Hartford Cas. Ins. Co. v. J.R. Mktg., L.L.C., 61 Cal. 4th 988, 353 P.3d 319, 321 (Cal. Aug. 10, 2015), the California
Supreme Court first acknowledges that under California law, if any claims in a third-party complaint against a
person or entity protected by a commercial general liability (CGL) insurance policy are even potentially covered
by the policy, the insurer must provide its insured with a defense to all the claims. It confirms that, pursuant
to its previous decision in Buss v. Superior Court, 16 Cal.4th 35, 939 P.2d 766 (Cal. 1997), the insurer may seek
reimbursement from the insured of defense fees and expenses solely attributable to the claims that were clearly
outside policy coverage. The Court noted that this case presented a different factual scenario than that in Buss,
which was fairly straightforward.
In this case, Hartford Casualty Insurance Company (Hartford)
initially refused to defend the insured against a third-party
lawsuit, claiming that the acts alleged in the complaint took
place prior to the policy period, and that certain of the
defendants were not insureds under the Hartford policy.
After a declaratory judgment where Hartford was found
to have a duty to defend, the Court also ordered (i) that
Hartford provide independent or Cumis counsel under a
reservations of rights; and (2) pursuant to an order that was
drafted by the law firm of Squire Sanders, the Cumis counsel
selected by the insureds, Hartford to pay all “reasonable and
necessary defense costs.”
Even though the order stated that because of the breach
of the duty to defend, Hartford would be precluded from
“invok[ing] the rate provisions of Section 2860,” the order
expressly preserved Hartford’s right to later challenge and
recover payments for “unreasonable and unnecessary”
charges by counsel. Hartford later alleged that the
independent counsel “padded” their bills by charging fees
that were, in part, excessive, unreasonable and unnecessary.
Hartford’s lawsuit was filed against the insured and against
Cumis counsel themselves.
The Court concluded that under the circumstances of this
case, the insurer may seek reimbursement directly from
Cumis counsel under the equitable principles of restitution
and unjust enrichment. If Cumis counsel, operating under a
court order that expressly provided that the insurer would
be able to recover payments of excessive fees, sought and
received from the insurer payment for costs that were
fraudulent, or were otherwise manifestly and objectively
useless and wasteful when incurred, Cumis counsel have
been unjustly enriched at the insurer’s expense. The Court
found that Cumis counsel provided no convincing reason
why they should be absolutely immune from liability for
enriching themselves in this fashion. Cumis counsel failed to
persuade that any financial responsibility for their excessive
billing should fall first on their own clients – insureds who
paid to receive a defense of potentially covered claims, not
to face additional rounds of litigation and possible monetary
exposure for the acts of their lawyers.
The Court made no review and determination of whether
the costs and fees incurred by Cumis counsel were, in
fact, excessive.
Tressler Comments
The California Supreme Court explicitly reserved this ruling to the unique and specific facts of this case, allowing pursuit
of Cumis counsel for reimbursement of unnecessary and unreasonable fees only in those circumstances where there is a
previous order in place allowing the insurer to seek such reimbursement. However, there is no dispute, as recognized by the
Court in its discussion of the background of this case, that California law under Buss, and later codified in statute, allows the
insurer to seek reimbursement of uncovered defense fees if it reserves its right to do so. That statute, Section 2860, also
requires that Cumis fees be necessary and reasonable.
It seems that the Court’s requirement of a previous court order allowing recovery, (which order in this case was drafted by
the Cumis counsel themselves) involves the issues of notice and fair warning to Cumis counsel of the potential for eventual
recovery against it. In the absence of such an order, which would likely be the case in most instances, the insurer may
attempt to execute a non-waiver agreement with the insured and Cumis counsel upon the acceptance of defense, that the
insurer reserves the right to proceed against the Cumis counsel directly to recover “unnecessary and unreasonable” fees
(uncovered defense costs may only be recovered from the insured itself). At the very least, if the insured and Cumis counsel
will not agree, reservation language to this effect should be included in all position letters to attempt to preserve the right
of recovery directly against the Cumis counsel. Whether the courts will expand the impact of this ruling beyond the facts of
this case remains to be seen.
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AUTHORS
Elizabeth Musser
Partner
Los Angeles
emusser@tresslerllp.com
Mary McPherson
Partner
Orange County
mmcpherson@tresslerllp.com
(No picture available)
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ktammaro@tresslerllp.com
Si-Yong Yi
Associate
Chicago
syi@tresslerllp.com
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This newsletter is for general information only and is not intended to provide and should not be relied upon
for legal advice in any particular circumstance or fact situation. The reader is advised to consult with an
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