EnergyNorth v. AEGIS

2001 DNH 021
CourtDistrict Court, D. New Hampshire
DecidedJanuary 31, 2001
DocketCV-97-064-M
StatusPublished

This text of 2001 DNH 021 (EnergyNorth v. AEGIS) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EnergyNorth v. AEGIS, 2001 DNH 021 (D.N.H. 2001).

Opinion

EnergyNorth v. AEGIS CV-97-064-M 01/31/01 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

EnergyNorth Natural Gas, Inc., Plaintiff

v. Civil No. 97-64-M Opinion No. 2001 DNH 021 Associated Electric & Gas Insurance Services Limited, et al.. Defendants

O R D E R

Having carefully considered plaintiff's motion to reconsider

(document no. 280), and having again considered applicable New

Hampshire law in light of the points made, as well as others not

specifically raised, I am persuaded that, because New Hampshire's

law is unclear, substantially identical insurance policy coverage

language has been construed differently by judges of this court.

Upon further reflection, I am not confident that the New

Hampshire Supreme Court adopted a "wrongful act" trigger-of-

coverage theory in Johnson Shoes1, notwithstanding the late Chief

Judge Devine's holding in Town of Peterborough v. Hartford Fire

1 U.S. Fidelity & Guar. Co., Inc. v. Johnson Shoes, Inc., 123 N.H. 148 (1983). Ins. C o ., 824 F.Supp. 1102, 1111-12 (D.N.H. 1993) ("in cases

involving the delayed manifestation of environmental

contamination. New Hampshire follows the rule that the time of

the occurrence is the time of the wrongful act which caused the

ultimate damage.").

The insurer in Johnson Shoes denied coverage in an

environmental contamination case on grounds that the policy only

covered "occurrences" taking place during the policy period.

"Occurrence" was defined as "an accident, including injurious

exposure to conditions, which results, during the policy period,

in bodily injury or property damage neither expected nor intended

from the standpoint of the insured." Johnson Shoes, 123 N.H. at

153. Oil "had apparently escaped from an underground storage

tank on premises leased by Johnson Shoes, and, after a period of

heavy rain [in 1973], spilled over onto neighboring property up

to one-half mile away." Johnson Shoes, 123 N.H. at 151. By that

time - the time of "manifestation" - the policy had terminated.

But, earlier in 1971 [while the policy was in effect], a company

maintenance man had reported to his superiors at Johnson Shoes

that he believed the underground oil tank was leaking. The trial

2 court found that the "occurrence" (presumably, discovery of the

leak) was within the policy period. On appeal, the New Hampshire

Supreme Court affirmed the trial court's determination. It did

so, however, without adopting a specific trigger-of-coverage

legal theory, and without much explanation beyond noting that

"there was sufficient evidence before the trial court to support

its finding that the occurrence took place during the coverage

period, and [the insurer] failed to meet its burden of

establishing noncoverage with regard to the timing of the

occurrence." Johnson Shoes, 123 N.H. at 153.

In Town of Peterborough, Judge Devine noted that a year

earlier he had ruled that New Hampshire followed the

"manifestation" trigger-of-coverage theory (i.e., that the time

of the "occurrence," as that term relates to insurance coverage

for environmental damage claims, is the time when the property

damage first becomes known to the claimant). See Suburban

Construction Co. v. Hartford Fire Ins., Civil Action No. 90-379-

SD (D.N.H. July 28, 1992). But, Judge Devine concluded in

Peterborough that the Johnson Shoes result was inconsistent with

a manifestation trigger-of-coverage legal theory, and was more

3 consistent with a "wrongful act" trigger theory. In my Order of

September 30, 2000, I followed Judge Devine's lead, agreeing that

Johnson Shoes necessarily adopted a wrongful act trigger theory.

Chief Judge Barbadoro has, however, read Johnson Shoes

another way. In EnergyNorth Natural Gas, Inc. v. AEGIS, et al..

Civil Action No. 95-591-B (September 30, 1998), Chief Judge

Barbadoro held that "at most [Johnson Shoes) stands for the

proposition that coverage can be triggered under an occurrence-

based policy by the occurrence of property damage while the

policy is in effect." That is, Johnson Shoes does not decisively

adopt any recognized trigger-of-coverage rule, but it is not

inconsistent with an "injury in fact" theory - i.e., the

occurrence causing property damage took place when the oil leaked

into the environment (as opposed to, for example, when the leak

was actually discovered). But, Johnson Shoes is arguably

consistent as well with a "wrongful act" theory, a "first

discovery" theory, a "knew or should have known" theory (i.e.,

the occurrence took place when the insured knew or should have

known of the property damage); and a "continuous trigger" theory

(i.e., the occurrence took place when the property was exposed to

4 the contaminant, and as the contaminant migrated, and at the time

of manifestation).

There is also another possibility. New Hampshire might

follow all rational trigger-of-coverage legal theories in

environmental contamination cases. As plaintiffs note. New

Hampshire's general rule relative to construction of insurance

policy language is set out in Trombly v. Blue Cross/Blue Shield

of New Hampshire-Vermont, 120 N.H. 764 (1980), and reguires that

courts "honor the reasonable expectations of the policy holder."

Id., at 771 (guoting Maqulas v. Travelers Ins. Co., 114 N.H. 704,

706 (1974)). In Trombly the court held that when terms of an

insurance contract are susceptible of two (or more) reasonable

interpretations, and one (or more) would provide coverage, the

interpretation that affords coverage must be adopted. While it

might be unusual, still, the New Hampshire rule might be that

insurance policy language must be construed consistently with any

rational and reasonable trigger-of-coverage legal theory under

which the disputed terms would afford coverage, on grounds that

the critical terms ("occurrence" and "accident") are necessarily

ambiguous since they can be reasonably construed under one

5 recognized trigger theory in a way that affords coverage and

under another theory in a way that precludes coverage. Thus,

under Trombly, the facts peculiar to each case could dictate

which legal theory of coverage the court would adopt, in order to

provide coverage in the face of contextually ambiguous terms.

Which legal trigger theory to apply is critical to proper

construction of the coverage language in both the accident-based

and occurrence-based policies at issue here. In nearly identical

circumstances, the Court of Appeals for the First Circuit made it

clear that "[t]he district court was obligated to determine which

of these trigger-of-coverage theories the [State] Supreme Court

would apply" in the case. CPC International, Inc. v. Northbrook

Excess & Surplus Ins. Co., 46 F.3d 1211 (1st Cir. 1995). In CPC

International, like this case, Rhode Island law was found to be

unclear, and pertinent state decisions were found to "raise more

guestions than they answer." Id. at 1221. Recognizing that

different jurisdictions have adopted at least seven different

legal theories governing when an occurrence policy provision is

triggered in the context of environmental damage claims, and

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Related

Town of Peterborough v. Hartford Fire Insurance
824 F. Supp. 1102 (D. New Hampshire, 1993)
Magulas v. Travelers Insurance
327 A.2d 608 (Supreme Court of New Hampshire, 1974)
Trombly v. Blue Cross/Blue Shield
423 A.2d 980 (Supreme Court of New Hampshire, 1980)
United States Fidelity & Guaranty Co. v. Johnson Shoes, Inc.
461 A.2d 85 (Supreme Court of New Hampshire, 1983)
Peerless Insurance v. Clough
193 A.2d 444 (Supreme Court of New Hampshire, 1963)
City of Manchester v. General Reinsurance Corp.
508 A.2d 1063 (Supreme Court of New Hampshire, 1986)
Curtis v. Guaranty Trust Life Insurance
566 A.2d 176 (Supreme Court of New Hampshire, 1989)

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2001 DNH 021, Counsel Stack Legal Research, https://law.counselstack.com/opinion/energynorth-v-aegis-nhd-2001.