Homestead Insurance v. American Empire Surplus Lines Insurance

Opinion

KITCHING, J.—

Introduction

“Claims made” insurance policies limit coverage to claims made during the policy period. An insurer thus bears responsibility only for the allowable claims filed during its policy period. Two insurers issued one-year policies to the insured, an escrow company. One complaint was filed against the escrow company during each of the policy periods. We reject the argument by the insurer of the later policy that the earlier policy should cover claims against the insured arising from both complaints. We hold that each insurance policy covers the claim made during its…