{"id":905675,"date":"2026-05-14T15:13:26","date_gmt":"2026-05-14T21:13:26","guid":{"rendered":"https:\/\/www.myconstructionexpert.com\/blog\/?p=905675"},"modified":"2026-05-14T15:13:29","modified_gmt":"2026-05-14T21:13:29","slug":"additional-insured-fourth-circuit-extends-coverage-to-contractor","status":"publish","type":"post","link":"https:\/\/www.myconstructionexpert.com\/blog\/additional-insured-fourth-circuit-extends-coverage-to-contractor\/","title":{"rendered":"Fourth Circuit Extends Coverage to Contractor,\u00a0American Bar Association"},"content":{"rendered":"\n

Brittany E. De Vries and Geoffrey B. Fehling | Hunton<\/a><\/p>\n\n\n\n

The Fourth Circuit in\u00a0APAC-Atlantic, Inc. v. Owners Insurance Co.\u00a0<\/em>recently endorsed expansive coverage for additional insureds<\/a>, interpreting \u201carising out of\u201d broadly under North Carolina law to extend coverage to a repaving company under its subcontractor\u2019s commercial general liability insurance policy. The court held that an additional insured\u2019s liability \u201carising out of\u201d a named insured\u2019s work in an additional-insured endorsement means liability \u201crelating to\u201d or \u201ccausally connected to\u201d the named insured\u2019s operations, rather than liability defined more narrowly as \u201ccaused by\u201d or \u201cthe fault of\u201d the named insured.<\/p>\n\n\n\n

This expansive interpretation aligns North Carolina with the majority view. That view affords broader coverage to additional insureds, even where the additional insured is found independently liable, so long as that liability is causally connected or incidental to the named insured\u2019s scope of work.<\/p>\n\n\n\n

Significance of Indemnitee Provisions to Trade Industries<\/strong><\/h4>\n\n\n\n

Additional-insured provisions allow access to someone else\u2019s insurance. Those insurance protections are also backstopped by indemnity obligations where one company assumes the risk of loss suffered by the indemnitee. Adding the indemnitee as an additional insured confirms that, even if the indemnitor is unable to indemnify, the indemnitee is still protected through insurance.<\/p>\n\n\n\n

While broad additional-insured coverage is important across industries, it is especially important in construction, where indemnity clauses are one of the most common methods of risk transfer. Stakeholders invariably encounter indemnity provisions in trade contracts between owners, general contractors, and subcontractors for residential and commercial projects of every scale.<\/p>\n\n\n\n

Owners typically will enter into a project contract with a general contractor that sets out the agreed-upon requirements, obligations, specifications, and scope of work for the parties. An owner\u2019s contract generally requires the general contractor to indemnify the owner for certain liabilities stemming from the project and the general contractor\u2019s work.<\/p>\n\n\n\n

While indemnity provisions vary, most say that the general contractor has to procure certain insurance limits or types to cover a construction project. Some may even specify particular forms, terms, or conditions. Contracts often require that the general contractor name the owner as an additional insured on these insurance policies. In turn, general contractors often enter into their own contracts with subcontractors, employing similar indemnity and insurance provisions in those agreements to transfer risk related to the subcontractors\u2019 work to that trade contractor. After these provisions are included in the contract, the next consideration is the contractual, and permissible, scope of indemnity.<\/p>\n\n\n\n

Restrictions on scope of indemnity clauses.<\/strong><\/h4>\n\n\n\n

The purpose of contractual indemnity obligations is to limit the additional insured\u2019s exposure to liabilities associated with the project. While the general presumption favoring freedom of contract gives companies a lot of leeway in entering into these indemnity arrangements, state statutes and law can restrict how much liability is allowed to be transferred. For instance, many courts will not enforce an indemnity provision that transfers an additional insured\u2019s sole and independent liability to the named insured.<\/p>\n\n\n\n

Several states have enacted \u201canti-indemnity\u201d statutes to limit the enforceability of certain trade contract indemnity clauses, and many of these statutes prohibit or limit risk transfer of another party\u2019s sole negligence.<\/p>\n\n\n\n

Other states permit contractors to transfer even more risk, including for the contractor\u2019s own sole or partial negligence, so long as that transfer is explicitly and unequivocally stated.<\/p>\n\n\n\n

As a result, states with anti-indemnity statutes demanding clear allocation of risk may not enforce an indemnification provision that is ambiguous or merely silent as to whether the indemnitor contemplated protecting the other party for its sole negligence. The language used in a contract and a policy is significant to allocate risk in a way that avoids a gap in risk transfer between the two, as well as to ensure agreed indemnity is not voided by applicable law.<\/p>\n\n\n\n

Role of additional-insured endorsements in indemnity and coverage.<\/strong><\/h4>\n\n\n\n

Additional-insured coverage helps fill the gaps in risk transfer. The coverage is in part responsive to the proliferation of state anti-indemnity statutes limiting the enforcement of indemnity clauses in trade contracts\u2014an additional-insured endorsement in an insurance policy may allow a contractor to still transfer risk and obtain defense and indemnity protection, depending on applicable law, even where state statute voids or limits direct indemnitee provisions.<\/p>\n\n\n\n

Additional-insured endorsements work to extend a named insured\u2019s coverage, or parts of that coverage, to another entity. The named insured is typically the primary policyholder and the entity that procures the insurance coverage. The additional insured under a policyholder\u2019s policy is granted coverage for certain risks and liabilities under that policy.<\/p>\n\n\n\n

Additional-insured coverage can be a useful tool for first- or third-party claims. For instance, if a named insured\u2019s plumbing work causes water damage to a renovation but also seeps into an owner\u2019s adjoining building not under renovation, the insured might seek coverage from its own insurer, with additional-insured coverage responding to any damage sustained in the adjoining structure. The coverage could also protect a company in the event of a third-party claim. Consider the scenario where an owner or general contractor is named an additional insured on a subcontractor\u2019s policy. In the event the subcontractor\u2019s employee is injured on the job and sues the owner or general contractor, additional-insured coverage may step in to cover the employee\u2019s claims against either additional insured.<\/p>\n\n\n\n

Additional-insured coverage is applicable for different types of insurance. An additional insured named in a builder\u2019s risk policy, for example, may have coverage for property damage on a job site connected with the named insured\u2019s work. Or an additional insured named in a commercial general liability policy may be afforded coverage under the named insured contractor\u2019s policy for third-party bodily injury or property damage resulting from an incident like a collapsed wall or an injured employee. We discuss below important additional-insured coverage developments under liability policies like those at issue in APAC<\/em>.<\/p>\n\n\n\n

Evolution of ISO Additional-Insured Endorsements<\/strong><\/h4>\n\n\n\n

Pre-2004 ISO additional-insured endorsement.<\/strong><\/p>\n\n\n\n

The language of the Insurance Services Office, Inc. (ISO) standardized additional-insured endorsement has changed over time. Although use of standardized ISO form language is not universally required\u2014and many times coverage is manuscript and customized for a particular transaction or project\u2014ISO forms are used often when coverage is underwritten.<\/p>\n\n\n\n

ISO has issued many different, evolving versions of additional-insured endorsements. The pre-2004 ISO form reads, in part, that coverage includes \u201cliability arising out of your work for that insured by or for you.\u201d This pre-2004 ISO endorsement employed the \u201carising out of\u201d language that the Fourth Circuit analyzed in APAC<\/em>. It granted cover to additional insureds for liability \u201carising out of\u201d the work of a named insured, which most states have interpreted expansively to mean an additional insured is covered so long as its liability was causally connected to the named insured\u2019s work.<\/p>\n\n\n\n

2004 ISO additional-insured endorsement revision.<\/strong><\/p>\n\n\n\n

In July 2004, ISO revised its form additional-insured endorsement to extend coverage for liability \u201ccaused, in whole or in part, by . . . [y]our acts or omissions.\u201d<\/p>\n\n\n\n

This marked a material shift in wording\u2014from \u201carising out of\u201d to \u201ccaused . . . by\u201d\u2014that also corresponds to the majority of jurisdictions finding that the pre-2004 ISO \u201carising out of\u201d language should have broad application and provide more coverage to additional insureds. It has been reported that ISO changed the language in the endorsement in part to limit courts\u2019 more expansive interpretation of \u201carising out of,\u201d to focus additional-insured coverage on liability caused by the named insured.<\/p>\n\n\n\n

Case Studies<\/strong><\/h4>\n\n\n\n

The distinction between \u201carising out of\u201d and \u201ccaused by\u201d language in additional-insured endorsements can have an outsized impact on potential coverage. We discuss three cases below demonstrating the differences in court interpretation of additional-insured endorsement language.<\/p>\n\n\n\n

Majority approach: APAC<\/em>.<\/strong><\/p>\n\n\n\n

The Fourth Circuit in APAC<\/em> concluded that North Carolina follows the majority approach of broadly construing \u201carising out of.\u201d<\/p>\n\n\n\n

In APAC<\/em>, the North Carolina Department of Transportation (NCDOT) retained a contractor, APAC-Atlantic, for highway repaving work. That work involved grinding down the roadway and replacing the top layer with new asphalt. The removal of existing asphalt made the roadways uneven, creating a potentially dangerous situation for motorists. The contractor hired a subcontractor to set out highway signs to warn motorists of the uneven pavement. Two motorcycle accidents ensued, resulting in separate personal injury suits. The contractor was sued for failure to place warning signs at locations in advance of the uneven lanes. The contractor settled and sought coverage from the subcontractor\u2019s liability insurer. The insurer refused, and the contractor filed suit seeking a declaration in favor of coverage under the subcontractor\u2019s policy.<\/p>\n\n\n\n

The subcontractor\u2019s additional-insured endorsement required the insurer to indemnify the contractor if the contractor\u2019s liability \u201carose out of\u201d the subcontractor\u2019s signage work. Relying on the Court of Appeals of Ohio in Davis v. LTV Steel Co., Inc.<\/em>, the trial court found the endorsement\u2019s \u201carising out of\u201d language required the subcontractor to cause the liability for there to be coverage. The trial court concluded that the contractor\u2019s liability was direct for its own conduct and not vicarious for work it delegated to its subcontractor to place signs as required by NCDOT.<\/p>\n\n\n\n

The Fourth Circuit reversed, holding that North Carolina expressly rejects treating \u201carising out of\u201d as synonymous with \u201ccaused by.\u201d The court reasoned that \u201carising out of\u201d is broader, requiring only some \u201ccausal connection\u201d to the named insured\u2019s work to entitle the additional insured to indemnification. It found that the contractor\u2019s failure to place warning signs in advance of the highway project was connected to the subcontractor\u2019s work to install signs. APAC<\/em> also noted the distinction, agreed with by the majority of jurisdictions, that while \u201carising out of\u201d when used in the grant of coverage extends coverage and should be interpreted broadly, that same language when used in an exclusion should be interpreted more narrowly to require \u201cproximate cause\u201d to exclude coverage.<\/p>\n\n\n\n

The Fourth Circuit rejected the lower court\u2019s reliance on Ohio precedent because North Carolina does not construe the operative language in the same way it is construed in Ohio\u2019s fault-based analysis in Davis<\/em>. Many jurisdictions follow this broader trend, with most finding that \u201carising out of\u201d an insured\u2019s work requires liability that is less than \u201cproximately caused by\u201d the insured but instead requires a causal connection between the insured\u2019s work and the additional insured\u2019s liability.<\/p>\n\n\n\n

Minority approach: Davis v. LTV Steel<\/em>.<\/strong><\/p>\n\n\n\n

While many states interpret \u201carising out of\u201d language in additional-insured endorsements broadly, that is not always the case. Under Davis, f<\/em>or example, Ohio interprets \u201carising out of\u201d the named insured\u2019s operations narrowly to encompass only liability for the tortfeasor\u2019s tortious conduct.<\/p>\n\n\n\n

The owner in Davis<\/em> sought coverage as an additional insured under its subcontractor\u2019s commercial general liability policy. At issue was liability in connection with injuries that one subcontractor employee sustained while cleaning tar sumps at a coke plant. The endorsement covered \u201cliability arising out of your operations or premises.\u201d The owner argued that \u201carising out of\u201d protects it from liability connected to the subcontractor\u2019s work, regardless of who was at fault for the incident. The court disagreed, holding that the endorsement\u2019s purpose was to \u201cprotect the additional insured . . . from being vicariously liable for the tortious acts of the named insured.\u201d<\/p>\n\n\n\n

Davis <\/em>represents the minority view that interprets \u201carising out of\u201d an insured\u2019s work to limit additional-insured coverage to only that arising from the fault of a named insured.<\/p>\n\n\n\n

The Fifth Circuit in Edwards v. Brambles Equipment Services<\/em>, interpreting Louisiana law, also found that \u201carising out of\u201d \u201cinsured\u2019s work\u201d endorsement language would not cover sole liability of an additional insured. However, Edwards<\/em> is distinct from Davis <\/em>in that the holding relied on a fact-specific determination that the additional insured\u2019s liability had no \u201cdirect relationship\u201d to the insured and the endorsement also contained specific exclusionary language that coverage did not encompass independent acts or omissions of the additional insured.<\/p>\n\n\n\n

In addition, some courts distinguish interpreting arising out of \u201coperations\u201d or \u201cwork\u201d differently from arising out of \u201cnegligence,\u201d as used in these endorsements, with the latter often being interpreted narrowly to require fault of the named insured, much like \u201ccaused by\u201d language in endorsements.<\/p>\n\n\n\n

\u201cCaused by\u201d interpretation: Burlington Insurance<\/em>.<\/strong><\/p>\n\n\n\n

Other jurisdictions, like New York, have taken a different approach since ISO\u2019s 2004 revision\u2014interpreting \u201ccaused by\u201d language in an additional-insured endorsement to limit coverage to that arising from the fault of a contractor.<\/p>\n\n\n\n

In Burlington Insurance Co. v. NYC Transit Authority<\/em>, the New York City Transit Authority (NYCTA) entered into a trade contract with concrete contractor Breaking Solutions, Inc. (BSI) to perform tunnel excavation work on a New York subway project.<\/p>\n\n\n\n

NYCTA\u2019s contract with BSI required that it be named an additional insured and that BSI use language from the ISO\u2019s \u201clatest\u201d form in the endorsement. The endorsement included the ISO\u2019s post-2004 \u201ccaused by\u201d language. The additional insureds sought coverage for liability associated with an incident. The Appellate Division found that BSI was not negligent for an explosion on an excavation site but that the explosion was a cause of an employee\u2019s injury. As a result, the insurer argued that the additional insureds were not covered\u2014the insurer argued that the additional insureds\u2019 liability was not \u201ccaused by\u201d the fault of BSI because BSI was not the proximate cause of the injury.<\/p>\n\n\n\n

The New York Court of Appeals agreed that the endorsement was \u201climited to those injuries proximately caused by BSI.\u201d While the \u201ccaused by\u201d language did not compel the \u201cnegligence of\u201d or \u201cproximate cause of\u201d the named insured, the court explained, it nevertheless meant more than a \u201cbut for\u201d causation.<\/p>\n\n\n\n

Burlington<\/em> shows that the \u201ccaused by\u201d language arising from the 2004 ISO modification to additional-insured endorsements can be construed narrowly. However, note that courts in New York still interpret \u201carising out of\u201d language broadly even where \u201ccaused by\u201d is interpreted more strictly, although the likelihood that they will do so is lessened by the fact that earlier ISO forms will not be in wide usage.<\/p>\n\n\n\n

Pay Attention to Language and Applicable Law<\/strong><\/p>\n\n\n\n

These cases\u2014which span a variety of outcomes that turn on a careful assessment of the facts, including policy language and governing law\u2014show that special attention should be given to additional-insured endorsements to ensure that expectations mesh with the reality of how that coverage will actually operate in practice. Boilerplate indemnity clauses in a trade contract requiring only that a contractor be added as an additional insured may not cut it to fully protect that contractor in the event of a claim.<\/p>\n\n\n\n

All project stakeholders\u2014from owners and consultants to general contractors and subcontractors\u2014should consider what law will govern a coverage dispute. Jurisdictions interpret additional-insured endorsements differently, and liability covered in one state may not be covered in another. Industry stakeholders seeking additional-insured coverage, especially risk managers and other professionals tasked with enacting robust and cohesive risk transfer solutions, should give careful attention to how contract and policy language may affect claim outcomes under additional-insured endorsements. Assessing policy language in tandem with governing law is important, both when procuring insurance programs and when negotiating trade contracts. Limits and sublimits should also be considered where multiple potential insureds may seek coverage for a single project or incident.<\/p>\n\n\n\n

Further, while ISO forms establish standardized policy language, insurers do not always use them. Nor are policyholders always bound by an insurer\u2019s proposed forms, which are often subject to negotiation during the underwriting process. Keep in mind that insurers often use their own manuscript or proprietary language, including additional-insured provisions, when placing and renewing policies. These manuscript versions sometimes can broaden or restrict coverage in unexpected ways and should be reviewed closely.<\/p>\n\n\n\n

The Fourth Circuit\u2019s APAC<\/em> decision reaffirms that the majority of jurisdictions are still of the opinion that \u201carising out of\u201d language found in an additional-insured endorsement demands a broader application of coverage.<\/p>\n\n\n\n

1 APAC-Atlantic, Inc. v. Owners Ins. Co.<\/em>, No. 24-1969, 2026 LX 40204 (4th Cir. Feb. 18, 2026).w<\/p>\n\n\n\n

2\u00a0See generally<\/em>\u00a0International Risk Management Institute (IRMI),\u00a0additional insured (AI)<\/a>\u00a0(\u201cIn liability insurance, additional insured status is commonly used in conjunction with an indemnity agreement between the named insured (the indemnitor) and the party requesting additional insured status (the indemnitee). Having the rights of an insured under its indemnitor\u2019s commercial general liability (CGL) policy is viewed by most indemnitees as a way of backing up the promise of indemnification.\u201d).<\/p>\n\n\n\n

3 See, e.g.<\/em>, Nat\u2019l Union Fire Ins. Co. v. Nationwide Ins. Co.<\/em>, 69 Cal. App. 4th 709, 717 (1999) (finding California Civil Code section 2782 voids indemnity clauses for sole negligence as they disincentivize contractors from undertaking \u201caccident-prevention measures involving [their] own negligence to avoid risk of harm to third parties\u201d).<\/p>\n\n\n\n

4 See, e.g.<\/em>, Cal. Civ. Code \u00a7 2782; Conn. Gen. Stat. \u00a7 52-572k; Colo. Rev. Stat. \u00a7 13-21-111.5; D.C. Code \u00a7 27A-202 (2023). For example, the states that comprise the Fourth Circuit\u2014Maryland, Virginia, West Virginia, North Carolina, and South Carolina\u2014have all adopted anti-indemnity statutes prohibiting indemnification for sole negligence as against public policy, void, and unenforceable. See <\/em>Md. Code Ann., Cts. & Jud. Proc. \u00a7 5-401 (noting the statute does not affect the validity of any insurance contract); Va. Code Ann. \u00a7 11-4.1 (same); W. Va. Code \u00a7 55-8-14 (same); N.C. Gen. Stat. Ann. \u00a7 22B-1 (same); S.C. Code Ann. \u00a7 32-2-10 (same).<\/p>\n\n\n\n

5 See, e.g.<\/em>, Reyburn Lawn & Landscape Designers, Inc. v. Plaster Dev. Co., Inc.<\/em>, 255 P.3d 268, 274 (Nev. 2011) (enforcing indemnity clause language transferring one party\u2019s sole negligence to another party, which in Nevada requires \u201can express or explicit reference to the indemnitee\u2019s own negligence\u201d); Doster Constr. Co., Inc. v. Marathon Elec. Contractors, Inc.<\/em>, 32 So. 3d 1277, 1283 n.2 (Ala. 2009) (requiring clear and unequivocal language); Keystone Specialty Servs. Co. v. Ebaugh<\/em>, 267 A.3d 1250, 1256 (Pa. Super. Ct. 2021) (citing Ruzzi v. Butler Petroleum Co.<\/em>, 527 Pa. 1, 7 (1991)) (same); Emery Waterhouse Co. v. Lea<\/em>, 467 A.2d 986, 993 (Me. 1983) (allowing transfer of sole negligence if clearly stated, but such provisions are disfavored by Maine courts).<\/p>\n\n\n\n

6 See<\/em>, e.g.<\/em>, Reyburn<\/em>, 255 P.3d at 274 (indemnification of the indemnitee against \u201cany and all claims\u201d was not sufficient to find the parties explicitly agreed to protect the indemnitee for its own negligence); Gunka v. Consol. Papers, Inc.<\/em>, 179 Wis. 2d 525, 531 (Ct. App. 1993) (indemnification for sole negligence of indemnitee permitted only if unambiguous).<\/p>\n\n\n\n

8 ISO is a national advisory organization that provides the insurance industry with nationwide standardization for insurance policy language, including for additional-insured endorsements. ISO form coverages, endorsements, conditions, and exclusions are used across the insurance industry to provide some level of uniformity to insurers, policyholders, regulatory agencies, and the legal system.<\/p>\n\n\n\n

10 Compare APAC<\/em>, 2026 LX 40204, at *3 (majority of jurisdictions find \u201carising out of\u201d extends coverage not only to vicarious liability for a subcontractor\u2019s work but also to independent liability connected to that work), with Davis v. LTV Steel Co., Inc.<\/em>, 716 N.E.2d 766 (Ohio Ct. App. 1998) (interpreting \u201carising out of\u201d language narrowly to cover only vicarious liability arising from the fault of the named insured).<\/p>\n\n\n\n

13 Davis v. LTV Steel Co., Inc.<\/em>, 716 N.E.2d 766 (Ohio Ct. App. 1998).<\/p>\n\n\n\n

14 APAC<\/em>, 2026 LX 40204, at *5.<\/p>\n\n\n\n

15 APAC<\/em>, 2026 LX 40204, at *6\u20137.<\/p>\n\n\n\n

16 APAC<\/em>, 2026 LX 40204, at *6 (citing Affinity Living Grp., LLC v. StarStone Specialty Ins. Co.<\/em>, 959 F.3d 634, 641 (4th Cir. 2020)).<\/p>\n\n\n\n

17 See, e.g.<\/em>, Fed. Ins. Co. v. Am. Hardware Mut. Ins. Co.<\/em>, 124 Nev. 319, 324 (2008); Cas. Ins. Co. v. Northbrook Prop. & Cas. Ins. Co.<\/em>, 150 Ill. App. 3d 472, 475 (1986); Container Corp. of Am. v. Md. Cas. Co.<\/em>, 707 So. 2d 733, 737 (Fla. 1998); Acceptance Ins. Co. v. Syufy Enters.<\/em>, 69 Cal. App. 4th 321, 328 (1999).<\/p>\n\n\n\n

19 Davis<\/em>, 716 N.E.2d at 737.<\/p>\n\n\n\n

20 See also Edwards v. Brambles Equip. Servs.<\/em>, No. 01-0892 Section \u201cL\u201d (2), 2002 U.S. Dist. LEXIS 16718, at *19 (E.D. La. Sept. 4, 2002), aff\u2019d<\/em>, 75 F. App\u2019x 929 (5th Cir. 2003).<\/p>\n\n\n\n

21 Edwards v. Brambles Equip. Servs.<\/em>, 75 F. App\u2019x 929 (5th Cir. 2003).<\/p>\n\n\n\n

22 Edwards<\/em>, 2002 U.S. Dist. LEXIS 16718, at *17.<\/p>\n\n\n\n

23 See, e.g.<\/em>, Harbor Ins. Co. v. Lewis<\/em>, 562 F. Supp. 800, 802 (D.C. Pa. 1983).<\/p>\n\n\n\n

24 See Burlington Ins. Co. v. NYC Transit Auth.<\/em>, 29 N.Y.3d 313 (2017).<\/p>\n\n\n\n

25 Burlington Insurance Co.<\/em>, 29 N.Y.3d at 317.<\/p>\n\n\n\n

26 Burlington Insurance Co.<\/em>, 29 N.Y.3d at 320.<\/p>\n\n\n\n

27 Burlington Insurance Co.<\/em>, 29 N.Y.3d at 321\u201324.<\/p>\n\n\n\n

28 See also, e.g.<\/em>, Maldonado v. Kiewit La. Co.<\/em>, 146 So. 3d 210, 219 (La. Ct. App. 1st Cir. 2014); James G. Davis Const. Corp. v. Erie Ins. Exch.<\/em>, 226 Md. App. 25, 43 (2015).<\/p>\n\n\n\n

\n\n\n\n

When one of your cases is in need of a construction expert, estimates, insurance appraisal or umpire services in defect or insurance disputes – please call Advise & Consult, Inc. at 801.641.8304, or email experts@adviseandconsult.net<\/a>.<\/strong><\/p>\n","protected":false},"excerpt":{"rendered":"

Brittany E. De Vries and Geoffrey B. Fehling | Hunton The Fourth Circuit in\u00a0APAC-Atlantic, Inc. v. Owners Insurance Co.\u00a0recently endorsed expansive coverage for additional insureds, interpreting \u201carising out of\u201d broadly under North Carolina law to extend coverage to a repaving company under its subcontractor\u2019s commercial general liability insurance policy. The court held that an additional… Continue reading Fourth Circuit Extends Coverage to Contractor,\u00a0American Bar Association<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","enabled":false},"version":2}},"categories":[10721],"tags":[382,9895,22],"class_list":["post-905675","post","type-post","status-publish","format-standard","hentry","category-insurance","tag-additional-insured","tag-advise-consult","tag-insurance","entry"],"jetpack_publicize_connections":[],"yoast_head":"\nFourth Circuit Extends Coverage to Contractor,\u00a0American Bar Association - 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