Safeco Surplus Lines Co. v. Employer's Reinsurance Corp.

Opinion

SIMS, Acting P. J.

This action for declaratory relief between two insurers involves errors and omissions insurance policies that provide coverage for claims made upon the insured. We must decide whether a claim is “made” upon an insured when a claim letter is dated by the claimant, as asserted by plaintiff Safeco Surplus Lines Company (Safeco), or when the letter is received by the insured, as maintained by defendant Employer’s Reinsurance Corporation (ERC). Like the trial court, we find that a claim is not “made” until it has been received; therefore, we affirm the trial court’s grant…