Vision One, LLC v. Philadelphia Indemnity Insurance

¶1 This case involves the proper interpretation of a “resulting loss” clause in an all-risk insurance policy. It also provides an opportunity to clarify application of the efficient proximate cause rule. The Court of Appeals overturned a jury verdict in favor of the insured, reasoning that the resulting loss clause did not apply in the absence of a secondary covered peril that proximately caused the loss. The court remanded for a jury determination as to the efficient proximate cause of the insured’s loss, holding that if the efficient proximate cause was not itself a covered peril, then the…