Document b3p8NBJv1mpKypDBQyZapq06
PLAINTIFF'S EXHIBIT
ST 070614 I
Court finds that asbestos
causes property damage
By MCHAEL SCHACHNER
Both policyholder and insurer and I think all new cases will fall attorneys call the May 20 decision in line--that asbestos contamina
SPRINGFIELD, I1L--An Illinois a landmark ruling.
tion is physical damage to property
Supreme Court ruling that n-
Policyholder attorneys laud the as defined under a CGL policy."
^estps .in_ bullcjingi constitutes decision, saying it confines what Mr. Skinner said.
property, damage andlhal an"'is- many triai end intermediate courts
Insurer attorneys agree that
bestos installer facing litigation have already ruled: Asbestos in courts nationwide will be in
from building owners is entitled to buildings constitutes property fluenced by the Illinois Supreme
defcase-fromits liability insurers damage as defined by the compre Court's ruling on insurers' duty to
will influence courts nationwide, hensive general liability insurance defend.
attorneys say.
policy.
However, they add that the scope
in unanimously affirming an ap
"This is a very significant ruling of the ruling is limited because it
pellate court decision, Illinois' because you have the first high did not address several other major
S3
highest court becomes the first court in any state ruling on the issues at the center of hundreds of state supreme court to rule that as issue of whether asbestos in build asbestos property damage eases.
bestos fibers in buildings consti ings constitutes property damage Those issues include whether in
tutes physical damage to tangible caused by an occurrence," noted surers must indemnify policyhold
property under comprehensive attorney William Skinner of Co ers for court awards to building
general liability insurance policies. vington it Burling in Washington, owners to cover the cost of identi
As a resultrthe court ruled, an D.C., which represoits Armstrong fying and removing asbestos and, if
installer that purchased CGL cov World Industries Inc. in asbestos so, which liability policies must re
erage over a 21-year period is enti lawsuits.
spond.
tled to a defense.
"The trend is dearly emerging--
CdKtmued
As a result of the ruling, WlUdn Insulation Co. of Mount Prospect,
HI., which installed spray-on fire
proofing materials containing as
bestos in hundreds of-public build
ings in Illinois end Iodiena between 1956 end 1970, is entitled
to a defense in nine pending as
bestos-related lawsuits filed by
schools and public entities.
The five insurers wrote a total ol
IB million of primary CGL limits
lor the installer from 1964 through
1994. Wilkin could trace its CGL
policies only as far back as 1964,
explained Wilkin co-counsel Craig
Mielke of Murphy Hupp Foote
Mielke 6c Klnnally in Aurora, ZU.
Hie duty-to-defead litigation
ensued when Baltimore-based United States Fidelity A Guaranty
Co. in 1964 refused to defend Wit-
kin in the nine underlying lew-
suits. USFIcG claimed asbestos
fibers only constitute a health haz
ard to humans and are not destruc tive to property.
The Insurer, whieh wrote
1500,000 of primary CGL limits for
Wilkin from Jan. 1, 1984, to Jan.
1, 1985, filed e lawsuit seeking a
summary judgment on the issue of
whether It had to defend the in
staller.
Wilkin then filed suit against
USF&G as well as its other CGL
insurers between 1964 and 1983
seeking a summery Judgment re
quiring the insurers to pay defense
costs. The other liability insurers,
though, have provided the installer
a defense under e reservation of
righta.
The other insurers are:
Argonaut Insurance Co. of
Menlo Park, Calif. Wilkin pur
chased 1900,000 in primary CGL
limits annually from ArgoaaotSDd
aoe of Argonaut's subaidjirins.be-
tween April.1, 1984, and April 1,
1973.
___
Commercial Union Insurance
Co. of Boston. From April 1, 1973,
through April 1, 1977, Wilkin pur
chased $500,000 in primary limits
annually from Commercial Union
and one of Its units.
e Aetna Casualty A Surety Co.
of Hartford, Conn. Wilkin pur
chased $500,000 of limits annually
from Aetna between April 1, 1977,
through Jan. 1,1962.
9 A Zurich Insurance Co. unit.
Wilkin purchased $500,000 ol CGL
limits from Zurich between Jan. 1,
1982, through Jan. 1,1984.
Defense costs are not included
within Wilkin's CGL limits, said
Wilkin co-counsel Stephan C. Haul
of Kirkland 6c EUis In Chicago,
who represented Wilkin before the
appellate and Supreme Court.
Wilkin also purchased exeem lia
bility coverage each year from var
ious insurers, with limits ranging
from fl million to' $5 million ex
cess of primary limits, Mr. Mielke
said.
A trial court granted summary
judgment for the insurers in Au
gust 1987.
But, Wilkin appealed, and an ap
pellate court reverted the decision
in December 1969, finding that the
nine undertying complaints "suffi
ciently alleged property damage
caused by an occurrence to bring
the cases within coverage by plain
tiff's insurance policies," court
papers say. Because no determination had
been
about Wilkin's liability
in the underlying cases, any deter mination of the Insurers' duty to
indemnify WUkin would be prema
ture, the appellate court ruled.
The Illinois Supreme Court, in an
opinion written by Justice Michael
Bilandic, e former Chicago mayor, affirmed the appellate court's de
cision.
The insurers had argued thet
there was no "event or accident"
resulting in property damage.
However, the court ruled that an
occurrence, defined as "an acci
dent including continuous or re
peated exposure to conditions that
result in property damage, neither
expected nor intended by the in
sured," is covered by a CGL pot-
icy.
"By virtue of the continuous or
repeated exposure to the condition
of asbestos fiber release, the build
ings end contents became conta
minated. It is the continuous expo
sure. . .that constitutes the
accident," Justice Bilandic wrote.
"The underlying complaints"
against Wilkin "allege that the
buildings and the contents therein
were contaminated by toxic as
bestos fibers. Therefore, the under
lying complaints allege physical
injury to tangible property. Thus,
we find that the underlying com
plaints allege potentially covered
property damage," Justice Bilandic
wrote.
The court also rejected insurers'
argument that they should not
have to provide a defense to Wilkin
because there were several cover
age exclusions in the policies writ
ten for Wilkin.
The Supreme Court ruled that a
pollution exclusion, a sistership
exclusion, a business risk exclu
sion and miscellaneous exclusions
in the policies were all inapplica
ble.
In addition, any ambiguity about
a policyholder's right to a defense
must be construed in favor of the
policyholder, the court found.
As a result of the ruling. Wilkin
Is entitled to unlimited defense
costs. Wilkin has accumulated at least $200,000 In defense costs to
date, primarily from
It-