After suffering business losses due to a hurricane, the insured's Civil Authority claim survived the insurer's motion to dismiss. Pathology Lab. v. Mt. Hawley Ins. Co., 2021 U.S. Dist. LEXIS 145129 (W.D. La. Aug. 3, 2021). Hurricane Laura devastated Lake Charles, Louisiana causing severe damage to the insured property as well as other properties within a mile of the insured property. All seven electrical transmission line corridors feeding Lake Charles were catastrophically damaged causing an extensive power outage. Government shutdown Orders prohibited the insureds' access to the Lab. The Orders were issued by the respective civil authorities both in anticipation of and as a result of damage and dangerous physical conditions expected from and actually resulting from Hurricane Laura and the continuation thereof. When the hurricane arrived, all businesses that were not essential to the recovery were ordered closed until electricity, water and sewer services were restored. As a result, the Lab was closed from August 27, 2020 toSeptember 8, 2020. The Lab sued for business income under the policy's Civil Authority provisions. Mt. Hawley moved to dismiss. Mt. Hawley argued that the Orders did not by their explicit terms close the Lab's business because closure was entirely dependent on the conditions of the described premises itself and whether it was safe to occupy. Mt. Hawley further argued that the mandatory Evacuation Order was issued in anticipation of property damage and therefore did not trigger coverage under the Civil Authority provision. The Lab argued that the Orders forced it to be closed and inaccessible to both employees and clients, triggering Civil Authority coverage. The court agreed that the first mandatory evacuation order before arrival of the hurricane did not immediately trigger the Civil Authority coverage because when ordered, there was no damage to other property. Civil Authority coverage was triggered, however, when Hurricane Laura struck Louisiana, causing severe damage to Lake Charles and the surrounding area. The Orders were caused by and cited as their inducement direct physical loss of and damage to property caused by Hurricane Laura other than at the Lab's premises, but including areas within a mile thereof. Consequently, the Lab demonstrated Civil Authority coverage and the motion to dismiss was denied.
from Insurance Law Hawaii https://ift.tt/3BrZKA3
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