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Travelers Indemnity Co. v. Whalley Construction Co.

Citations: 287 S.E.2d 226; 160 Ga. App. 438; 1981 Ga. App. LEXIS 2986Docket: 62395

Court: Court of Appeals of Georgia; September 23, 1981; Georgia; State Appellate Court

Narrative Opinion Summary

In the case of Travelers Indemnity Company v. Whalley Construction Company, Inc., the Court of Appeals of Georgia considered a dispute over insurance coverage following a construction incident involving a crane collapse. The plaintiffs, Georgia Infirmary Non-Profit Housing Corporation and Whalley Construction Company, sought coverage under two insurance policies held with Travelers Indemnity Company. The incident resulted in building damage, prompting the plaintiffs to claim coverage, which Travelers denied, arguing the policy exclusions for vehicle-related damages applied. The trial court granted summary judgment for the plaintiffs, interpreting the policy terms to include coverage for the damage caused by the crane, classified as a vehicle. The court emphasized that insurance exclusions must be clear and unambiguous to be enforceable, and ambiguities should favor the insured. Travelers appealed, maintaining that the crane's operation by a subcontractor, an additional insured, should exclude coverage for Whalley. The appellate court affirmed the decision, highlighting the importance of clear policy language and ruling that the exclusion language was not sufficiently explicit to deny coverage. Consequently, summary judgment in favor of the plaintiffs was upheld, allowing recovery under the insurance policy for the damages incurred.

Legal Issues Addressed

Coverage of Additional Insureds

Application: The court addressed whether a subcontractor's operation of a crane, as an additional insured, affected the general contractor's coverage under the policy.

Reasoning: The court did not resolve the broader implications regarding damages caused by employees of any insured, focusing instead on the plaintiffs' claim for damage to their property resulting from the crane operated by the subcontractor.

Definition of 'Vehicle' under Insurance Policy

Application: The court determined that a mobile crane qualifies as a vehicle, affecting coverage under the insurance policies involved in the case.

Reasoning: The court found that one policy covered damages from vehicles, while another explicitly excluded such losses, citing relevant case law indicating that a mobile crane qualifies as a vehicle.

Exclusion Clauses in Insurance Policies

Application: The court ruled that exclusions must be clear and unequivocal to be enforceable, and any ambiguity is to be resolved in favor of covering the insured.

Reasoning: Any exclusions proposed by the insurer are to be interpreted liberally in favor of the insured and strictly against the insurer, unless the exclusions are clear and unequivocal.

Insurance Policy Interpretation

Application: The court emphasized that insurance policies must be drafted in clear language, and any ambiguities are to be interpreted in favor of the insured.

Reasoning: The court found this interpretation to be overly strained, emphasizing that insurance policies must be drafted in clear language.