American Guarantee and Liability Insurance Company v. Victory Highlands Condominium Association, Inc.

CourtNew Jersey Superior Court Appellate Division
DecidedDecember 26, 2024
DocketA-3321-22
StatusUnpublished

This text of American Guarantee and Liability Insurance Company v. Victory Highlands Condominium Association, Inc. (American Guarantee and Liability Insurance Company v. Victory Highlands Condominium Association, Inc.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Guarantee and Liability Insurance Company v. Victory Highlands Condominium Association, Inc., (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3321-22

AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY,

Plaintiff-Respondent,

v.

VICTORY HIGHLANDS CONDOMINIUM ASSOCIATION, INC., and MARSHALL & MORAN, LLC,

Defendants,

and

LARRY CHENAULT,

Defendant-Appellant. _______________________________

Argued on October 29, 2024 – Decided December 26, 2024

Before Judges Gilson, Firko and Augostini.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. L-8231-18. Carl A. Salisbury argued the cause for the appellant (Bramnick, Rodriguez, Grabas, Arnold & Mangan, attorneys; Carl A. Salisbury, on the briefs).

Gabriel E. Darwick argued the cause for the respondent (White and Williams, LLP, attorneys; Gabriel E. Darwick and James Layman, on the brief).

PER CURIAM

This case involves an insurance dispute regarding liability coverage for

toxic mold exposure under commercial umbrella liability policies. 1 Defendant

Larry Chenault (Chenault) appeals from two orders: (1) an October 17, 2019

order granting reconsideration of plaintiff American Guarantee and Liability

Insurance Company's (Zurich)2 motion for summary judgment; and (2) a May

24, 2023 order, which was entered following a bench trial, and which, in relevant

part, denied coverage under the consumption exception to the mold exclusion,

the first manifestation rule, and continuous trigger theory.

1 "[Commercial General Liability] policies protect business owners against liability to third parties, encompassing a wide variety of potential claims." Cypress Point Condo. Ass'n v. Adria Towers, L.L.C., 226 N.J. 403, 408 n.1 (2016) (citing 3 Jeffrey E. Thomas, New Appleman on Insurance, Law Library Edition § 16.02[3][a][i] (2015)). 2 At oral argument, counsel for plaintiff American Guarantee and Liability Insurance Company explained that Zurich American Insurance Company (Zurich) is the parent company. Thus, we refer to plaintiff as Zurich in this opinion. A-3321-22 2 Chenault lived in a condominium complex owned by Victory Highlands

Condominium Association (VHCA). Allegedly he suffered injuries after being

exposed to toxic mold caused by a crack in the foundation of the building, which

caused water to seep into Chenault's condo. In 2010, Chenault sued VHCA and

its property manager, Marshall and Moran (M&M). The parties settled in May

2012, and the settlement agreement contained a provision that the lawsuit could

be reopened if Chenault found liability insurance policies issued to VHCA or

M&M.

In 2014, the court permitted Chenault to reopen the lawsuit, and he filed

an amended complaint against VHCA, M&M, and four liability insurers that had

issued policies to VHCA during the applicable period. In December 2018,

Chenault settled with VHCA and three of the insurance carriers but did not settle

with Zurich. The December 2018 settlement agreement superseded the

settlement agreement of May 2012.

On May 7, 2018, Zurich filed the present declaratory judgment action

against VHCA and M&M, and Chenault was named an interested party. VHCA

and M&M did not participate in the case. On May 24, 2019, the motion judge

denied the parties' cross motions for summary judgment. However, on October

17, 2019, the motion judge granted Zurich's motion for reconsideration and held

A-3321-22 3 that Appleman's Rule, "pursuant to which the loss is covered if a covered cause

starts or ends the sequence of events leading to the loss," 3 did not apply to the

commercial liability insurance policies such as those issued by Zurich.

Following a bench trial on the issue of the reasonableness of the settlement

and on whether the consumption exception to the mold exclusions applied, the

trial judge held the settlement was reasonable and the exception to the mold

exclusion did not apply. Therefore, the trial judge concluded Zurich had not

breached its duty to defend or indemnify.

We have considered these arguments in light of the record and applicable

legal standards. We affirm.

I.

We briefly recount the salient, undisputed facts and procedural history

derived from the record. From 1991 until Spring 2009, Chenault lived in a condo

he purchased in a complex owned and managed by VHCA. During this time,

water infiltrated the unit through a leak in the basement. After complaining

about the problem and requesting that it be remediated, VHCA attempted some

remediation work. In March 2009, the premises were inspected, and significant

3 Flomerfelt v. Cardiello, 202 N.J. 432, 447 (2010). A-3321-22 4 toxic mold levels were discovered. Chenault moved out of the property and

never resided there again.

A. Underlying Negligence Litigation.

On April 15, 2010, Chenault filed a complaint against VHCA and M&M

for the injuries he suffered because of the mold in the condo. He asserted claims

for negligence; nuisance; breach of the implied right of quiet enjoyment; breach

of a contractual obligation or the implied covenant of good faith and fair dealing

to repair an exterior leak; and breach of the implied warranty of habitability.

Chenault specifically alleged that he suffered personal injuries because he

"inhaled toxic mold" as follows: "As a direct and proximate result of the actions,

or inactions, of the [d]efendants, which were willful, wanton, reckless, and

intentional, [p]laintiff's unit became uninhabitable and he inhaled toxic mold

and sustained severe permanent injuries." In addition to personal injuries,

Chenault alleged damage to his real and personal property.

During the years Chenault lived in the condo, VHCA purchased s everal

insurance policies through several different insurance companies, including five

commercial umbrella liability policies issued by Zurich to VHCA between June

1, 2005 and June 1, 2010.

A-3321-22 5 The Zurich policies provided two forms of coverage: Coverage A

provided "excess follow form liability insurance," and Coverage B provided

"umbrella liability insurance." Coverage A did not apply because the underlying

primary liability policies had mold exclusions and did not provide primary

liability coverage for Chenault's clams. Coverage B, the umbrella policy,

provided:

Under Coverage B, we will pay on behalf of the insured, sums as damages the insured becomes legally obligated to pay by reason of liability imposed by law or assumed under an insured contract because of bodily injury, property damage, or personal or advertising injury covered by this insurance but only if the injury, damage or offense arises out of your business, takes place during the policy period of this policy and is caused by an occurrence happening anywhere.

However, each of the five Zurich policies contained a fungus liability

exclusion provision, which restricted coverage for mold damages. Beginning

with the two policies covering the periods June 1, 2005 to June 1, 2006, and

June 1, 2006 to June 1, 2007, the exclusion in those policies stated:

FUNGUS LIABILITY EXCLUSION

....

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American Guarantee and Liability Insurance Company v. Victory Highlands Condominium Association, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-guarantee-and-liability-insurance-company-v-victory-highlands-njsuperctappdiv-2024.