Narrative Opinion Summary
Liberty Mutual Fire Insurance Company contested a summary judgment that required it to pay MI Windows and Doors, Inc. $3.4 million under a commercial general liability (CGL) policy. The case arose from MI's settlement of defective-product lawsuits filed by condominium associations after storm damage revealed compromised doors. The trial court determined that the 'your product' exclusion did not apply to doors altered with transoms, awarding MI $2 million based on two identified occurrences: the distribution of defective products and the alteration with transoms. However, the appellate court found the trial court's interpretation of the 'your product' exclusion flawed, arguing that the alteration of doors with transoms did not significantly change their nature or function. The appellate court conducted a de novo review, reversing the damages related to the exclusion while affirming other aspects of the ruling. The decision referenced previous Florida cases, illustrating the nuanced application of product alterations affecting insurance coverage. The outcome underscored the necessity for precise interpretation of policy exclusions in determining liability and coverage under CGL policies.
Legal Issues Addressed
Alteration of Product and Its Impact on Insurance Coveragesubscribe to see similar legal issues
Application: The trial court ruled that the exclusion did not apply because the transoms materially altered the doors, but the appellate court disagreed, reversing damages related to this exclusion.
Reasoning: The trial court determined that the 'your product' exclusion did not apply because the addition of transoms to sliding glass doors materially altered them, rendering them no longer MI's product.
Definition of 'Occurrence' in CGL Policiessubscribe to see similar legal issues
Application: The trial court identified two occurrences under the CGL policy: the distribution of defective products and the alteration of doors with transoms, leading to a $2 million award for MI.
Reasoning: The CGL policy covers occurrences defined as accidents, with a $500,000 deductible for each occurrence. The trial court identified two occurrences: the distribution of defective products and the alteration of doors with transoms.
Interpretation of 'Your Product' Exclusion in CGL Policiessubscribe to see similar legal issues
Application: The appellate court found merit in Liberty's challenge to the trial court's interpretation of the 'your product' exclusion, asserting it was clear and unambiguous.
Reasoning: The trial court incorrectly determined that the 'your product' exclusion in Liberty's commercial general liability (CGL) policy did not apply to the costs associated with replacing MI's defective doors.
Standard of Review for Summary Judgmentssubscribe to see similar legal issues
Application: The appellate court reviewed the summary judgment de novo, finding merit in Liberty's challenge regarding the applicability of the 'your product' exclusion.
Reasoning: The appellate court reviews summary judgments de novo and found merit in Liberty's challenge regarding the exclusion's applicability.