Spaulding Composites Co. v. Aetna Cas. and Surety Co.

The opinion of the Court was delivered by

LONG, J.

In this appeal, we revisit the “continuous trigger” and “pro rata allocation” doctrines we adopted to address complex environmental insurance coverage issues in Owens-Illinois, Inc. v. United Ins. Co., 138 N.J. 437, 650 A.2d 974 (1994). More particularly, we have been asked how those principles affect the validity of a “noncumulation” clause in a comprehensive general liability policy that is invoked by an insurer to restrict its exposure on nine years of coverage to a single policy limit. We hold that the rules enunciated in Owens-Illinois and…