Florida Appellate Court Narrows Exception to Four Corners Rule

The general rule for determining whether a duty to defend exists for a particular claim is easily stated. If the allegations against the insured fall within the scope of coverage afforded by a liability policy, then the insurer has a duty to defend its insured. This general rule is commonly referred to as the four corners rule.

However, insurers frequently face a dilemma in determining whether they have a duty to defend where the allegations in a tendered suit arguably fall within the scope of coverage under …

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The Irony of Not Fixing What Isn’t Broken: Wisconsin Supreme Court Refuses to Consider Extrinsic Evidence of Subcontractors’ Involvement in Replacement of Damaged Well Pump

Bootstrapping upon its decision in Marks v. Houston Casualty Co., 2016 WI 53, the Wisconsin Supreme Court in Water Well Solutions Service Group Inc. v. Consolidated Insurance Co., 2016 WI 54, affirmed summary judgment in favor of the insurer. The Supreme Court concluded, based upon a four-corners analysis, that the policy’s “your product” exclusion barred coverage entirely for the underlying lawsuit. The Supreme Court further rejected the insured’s invitation to recognize an exception to the four-corners rule to allow courts to examine extrinsic …

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