American Casualty Co. of Reading v. Belcher

Summary

The Eleventh Circuit affirmed summary judgment for American Casualty, holding that multiple patients’ infection claims arising from unsanitary pharmaceutical repackaging constituted a single claim under the insurance policy’s related-claims provision. Applying Florida law, the court found the claims logically or causally connected by common facts, personnel, procedures, and purpose. The court also rejected the argument that the policy’s aggregate limit was illusory.

Holdings

1. The defendants' claims were related because they arose out of acts, errors, or omissions that were logically or causally connected by numerous common facts, circumstances, and decisions. The policy therefore required all claims to be treated as a single claim subject to the $1 million single-claim limit.
2. The aggregate limit was not illusory because the policy provided circumstances in which claims could be unrelated to the repackaging conduct and trigger the aggregate limit, and because application of the related-claims provision did not eliminate all or virtually all coverage.

Questions Presented

1. Whether the defendants' injuries arose out of related acts, errors, or omissions under the insurance policy and therefore constituted a single claim subject to the $1 million per-claim limit.
2. Whether applying the related-claims provision made the policy's $3 million aggregate limit illusory under Florida law.

Disposition

affirmed