Nandorf, Inc. v. CNA Insurance Companies

Plaintiff, Nandorf, Inc. (Nandorf), appeals from the trial court’s dismissal of its declaratory judgment action against its insurer, defendant CNA Insurance Companies (CNA). The complaint sought reimbursement of attorney fees incurred by Nandorf in monitoring the defense provided by attorneys retained by CNA in a civil action brought against Nandorf by third parties. CNA provided the defense but reserved its rights to deny coverage for punitive damages. Nandorf now contends that the defense provided by CNA pursuant to its reservation of rights created a conflict of interest which entitled…