In Gemini Ins. Co. v. Constrx Ltd., NO. 14-00355 DKW-RLP, 2018 WL 7508264 (D. Haw. September 24, 2018), the Court determined that a commercial general liability carrier owed a duty under its liability insurance policy to defend its policyholder in an arbitration. The reason? The policyholder could be subjected to liability and the liability policy had to provide defense coverage as a result. Simple as that, the Court ruled in effect.
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