National Union Fire Insurance v. Northwest Youth Services

Connie LaValley sued her therapist, Paul Ritchie, and Northwest Youth Services (NWYS), Ritchie’s employer, alleging that Ritchie had entered into an improper sexual relationship with her.1 National Union Fire Insurance Company, NWYS’s insurer, then commenced this declaratory judgment action, contending that it had no duty to defend or indemnify Ritchie and NWYS on LaValley’s claims. National Union argued that its insurance policies provided coverage for NWYS employees only when they were acting within the scope of their employment and that the trial court in the liability action had…