AIG Specialty Insurance Company v. SITE Centers Corporation

CourtDistrict Court, N.D. Ohio
DecidedOctober 24, 2025
Docket1:22-cv-00361
StatusUnknown

This text of AIG Specialty Insurance Company v. SITE Centers Corporation (AIG Specialty Insurance Company v. SITE Centers Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AIG Specialty Insurance Company v. SITE Centers Corporation, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION AIG SPECIALTY INSURANCE ) CASE NO. 1:22CV361 COMPANY, ) ) ) Plaintiff, ) JUDGE CHRISTOPHER A. BOYKO ) vs. ) ) SITE CENTERS CORPORATION, ) OPINION AND ORDER ) ) Defendant. ) CHRISTOPHER A. BOYKO, J.: This matter comes before the Court upon the Renewed Motion (SEALED ECF DKT #70 & REDACTED ECF DKT #71) of Plaintiff AIG Specialty Insurance Company (“AIG”) for Summary Judgment. For the reasons that follow, the Motion is denied. I. BACKGROUND Twenty-five years ago, Defendant SITE Centers Corporation (“SITE”), formerly known as DDR Corporation, constructed a parking lot at the Stow Community Shopping Center in Stow, Ohio. The parking lot was constructed using steel mill slag as a subbase. The Ohio EPA (“OEPA”) issued a Notice of Violation (“NOV”) to SITE that stormwater runoff from the parking lot that migrated through the slag subbase was causing pollutants to invade the waters of the State of Ohio. Ultimately, in response to the NOV, SITE removed and replaced a portion of the parking lot including the slag subbase. SITE seeks to recover its costs for removal under a Pollution Liability Insurance Policy (“Policy”) with its insurer, AIG. AIG issued to SITE a Pollution Legal Liability Real Estate Policy (CRE 25417764) effective from December 31, 2014 to December 31, 2017. The parking lot at issue is owned by SITE. On or about March 21, 2016, after a rain, stormwater with a pH of greater than 12.5 was released from the property’s stormwater management system and flowed into a tributary of Fish Creek. The OEPA issued an NOV to SITE for violations of Ohio Revised Code (“O.R.C.”)

Sections 6111 and 3734 due to discharge into waters of the State of Ohio, which created a buildup of flocculate (clumps) in the drainage ditch flowing into Fish Creek. The NOV instructed SITE to take initial abatement actions including: “Determine the source of the D002 waste and work to eliminate the generation of the waste.” (Emphasis added). The OEPA ordered SITE to stop discharging polluted stormwater into the waters of the State of Ohio and to clean the drainage ditch. SITE hired ATC Group Services to investigate. ATC installed a plug to hold water in a pond so it could be treated prior to discharge into the

drainage pipe. ATC’s scientific investigation, testing and borings determined that the likely source of contamination was the slag used as a subbase material for the parking lot. SITE set up a temporary stormwater treatment system while it explored ways to prevent further discharges into the waters of Ohio. On March 22, 2016, SITE informed AIG of the violations and demanded coverage under the policy. AIG ultimately paid $479,286.56 for the remediation of discharge contaminants in the drainage ditch and waters of the State of Ohio and to treat contaminated water until clean-up was complete. However, AIG has refused coverage for SITE’s ultimate removal of the slag and

replacement of the parking lot. On March 4, 2022, AIG filed the within Declaratory Judgment action seeking a judicial declaration that there is no coverage under the Policy and that AIG has no obligation to pay sums -2- to SITE for Clean-Up Costs. SITE has filed a Counterclaim for Breach of Insurance Contract and Declaratory Judgment that AIG is liable to cover all costs for Clean-Up. Those costs exceed the Policy Limits of $3,000,000. On May 23, 2025, AIG filed its Renewed Motion for Summary Judgment requesting the

Court to declare that AIG has no coverage obligation to SITE. AIG asks the Court to find that there is no coverage because the Clean-Up Costs: (1) did not result from a Pollution Condition (instead, they are prophylactic); (2) are not reasonable and necessary, in that there is a far more cost-efficient way to address the slag leachate; (3) are not required by Environmental Laws; (4) were incurred without AIG’s consent in violation of the Policy’s “voluntary payments” condition; (5) are precluded from coverage by Exclusion I because the alleged Pollution Condition existed prior to the Policy’s Inception Date and was known to SITE but not disclosed

to AIG; and (6) allegedly result from a Pollution Condition that began long before the Policy’s 2014 Continuity Date. The Court will address each specific reason in turn. However, the Court is compelled first to address AIG’s request for reconsideration (ECF DKT #70 at 17-18) of the Daubert ruling of March 28, 2025. After briefing and an oral hearing, the Court denied AIG’s Motion to Exclude the report and testimony of SITE’s expert, Michael J. Connolly. (ECF DKT #64). Relying upon the reasons detailed in the original Motion to Exclude, AIG insists again that Connolly is not qualified to offer reliable and relevant opinions. Aside from the tardiness of this

request, AIG makes the same arguments that were found unpersuasive before and inappropriately inserts them within its Renewed Motion for Summary Judgment. “District courts have authority both under common law and Rule 54(b) to reconsider -3- interlocutory orders and to reopen any part of a case before entry of final judgment.” Rodriguez v. Tenn. Laborers Health & Welfare Fund, 89 F.App’x 949, 959 (6th Cir. 2004). Nevertheless, motions for reconsideration “serve a limited purpose and should be granted for one of three reasons: (1) because of an intervening change in controlling law; (2) because evidence not

previously available has become available; or (3) because it is necessary to correct a clear error of law or preventing manifest injustice.” Boler Co. v. Watson & Chalin Mfg. Inc., 372 F.Supp.2d 1013, 1024-25 (N.D.Ohio 2004), quoting General Truck Drivers, Local No. 957 v. Dayton Newspapers, Inc., 190 F.3d 434, 445 (6th Cir. 1999) (Clay, J. dissenting), cert. denied, 528 U.S. 1137 (2000). AIG establishes none of those justifications; and the Court declines to reconsider its Daubert ruling regarding SITE’s expert. II. LAW AND ANALYSIS

Standard of Review Summary judgment shall be granted only if “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” See Fed.R.Civ.P. 56(a). The burden is on the moving party to conclusively show no genuine issue of material fact exists. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986); Lansing Dairy. Inc. v. Espy, 39 F.3d 1339, 1347 (6th Cir. 1994). The moving party must either point to “particular parts of materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations, admissions, interrogatory answers, or other

materials” or show “that the materials cited do not establish the absence or presence of a genuine dispute, or that an adverse party cannot produce admissible evidence to support the fact.” See Fed.R.Civ.P. 56(c)(1)(A), (B). A court considering a motion for summary judgment must view -4- the facts and all inferences in the light most favorable to the nonmoving party. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986). Once the movant presents evidence to meet its burden, the nonmoving party may not rest on its pleadings, but must come forward with some significant probative evidence to support its claim. Celotex, 477 U.S.

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AIG Specialty Insurance Company v. SITE Centers Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aig-specialty-insurance-company-v-site-centers-corporation-ohnd-2025.