Misrepresentations Are Not An “Occurrence”

Two recent cases add to the growing list of courts nationwide that have held that alleged false or deceptive statements are not covered by a homeowners’ or commercial general liability policy. The cases are Jennings v. State Farm Lloyds, 2006 WL 66408 (Tex.App.-Austin, January 12, 2006) and Green v. State Farm Fire & Casualty Co., 2005 WL 3556720 (Utah App., December 30, 2005). In both cases, the misrepresentations failed to produce either bodily injury or property damage within the meaning of the policy, and therefore no “occurrence” as required for coverage.

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Filed under Duty to Defend, Duty to Indemnify, Liability Policies

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