Lords Landing v. Continental Ins Co

CourtCourt of Appeals for the Fourth Circuit
DecidedSeptember 13, 1999
Docket98-1639
StatusUnpublished

This text of Lords Landing v. Continental Ins Co (Lords Landing v. Continental Ins Co) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lords Landing v. Continental Ins Co, (4th Cir. 1999).

Opinion

UNPUBLISHED

UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

LORDS LANDING VILLAGE CONDOMINIUM COUNCIL OF UNIT OWNERS, Plaintiff-Appellee, No. 98-1639 v.

CONTINENTAL INSURANCE COMPANY, Defendant-Appellant.

Appeal from the United States District Court for the District of Maryland, at Greenbelt. Peter J. Messitte, District Judge. (CA-94-3377-PJM)

Argued: June 10, 1999

Decided: September 13, 1999

Before WIDENER, NIEMEYER, and TRAXLER, Circuit Judges.

_________________________________________________________________

Reversed by unpublished per curiam opinion.

_________________________________________________________________

COUNSEL

ARGUED: Jeffrey Roger Schmieler, SAUNDERS & SCHMIELER, Silver Spring, Maryland, for Appellant. Kevin Thornton, KAPLAN & KAPLAN, P.A., Baltimore, Maryland, for Appellee.

_________________________________________________________________ Unpublished opinions are not binding precedent in this circuit. See Local Rule 36(c).

_________________________________________________________________

OPINION

PER CURIAM:

The issue presented by this appeal is whether a standard compre- hensive general liability ("CGL") insurance policy provides a condo- minium developer coverage for the costs of repairing faulty workmanship performed by the developer's subcontractors. We hold that the policy does not provide such coverage and therefore reverse the judgment of the district court finding coverage.

In May 1994, the Council of Unit Owners at Lords Landing Village Condominium complex ("Unit Owners") sued the developer of the complex, Wellington Homes, for faulty workmanship, including, inter alia, failure to prime wood before painting, causing the wood to rot. The faulty work had been performed for Wellington Homes by sub- contractors. Following a trial, the jury returned a verdict in favor of the Unit Owners and against Wellington Homes in the amount of $1.1 million, based on breaches of express and implied warranties and vio- lations of the Maryland Consumer Protection Act.

When the Unit Owners were unable to collect the $1.1 million judgment from Wellington Homes, they brought this action directly against Wellington Homes' insurer, Continental Insurance Company, which had issued a CGL insurance policy to Wellington Homes. That policy, which was an industry standard CGL policy, provided cover- age for sums that Wellington Homes became legally obligated to pay because of "property damage" caused by an"occurrence." The policy defined the term "occurrence" to be "an accident, including continu- ous or repeated exposure to substantially the same general harmful conditions."

Relying on the Maryland Court of Appeals' recent decision in Sheets v. Brethren Mut. Ins. Co., 679 A.2d 540 (1996) (holding that the proper standard for determining whether a negligent act is an "ac-

2 cident" under a CGL policy is subjective -- whether the damage was unforeseen or unexpected by the insured), the district court concluded that the CGL policy Continental Insurance issued to Wellington Homes covered the damages caused by the subcontractors' faulty workmanship because the faulty workmanship amounted to an "oc- currence" as defined by the policy. The court concluded that such damages were neither intended nor expected by Wellington Homes and that, therefore, under the subjective standard in Sheets, such dam- ages were caused by an "accident" as defined by the policy.

On appeal, Continental Insurance argues that Sheets does not apply because the damages in Sheets resulted from negligent misrepresenta- tion, whereas the loss here resulted from faulty workmanship amount- ing to a breach of warranty and violation of the state Consumer Protection Act. Relying on the post-Sheets decision in Lerner Corp. v. Assurance Co. of America, 707 A.2d 906 (Md. App. 1998), which interpreted Sheets in a context more closely analogous to that before us, Continental Insurance argues that the repair and replacement costs for the faulty workmanship are economic losses resulting from failure to satisfy a contractual bargain and thus are not losses covered by the CGL policy. It argues that CGL policies are not intended as surety bonds that insure contractual obligations and that to order Continental Insurance to pay for the repairs would convert its policy into a perfor- mance bond, which was never intended by the parties. We agree.

In Sheets, the court was simply concerned that an objective stan- dard for defining the term "accident" in a CGL policy, rather than a subjective standard, would create an anomalous situation where insur- ance policies would cover only damages for which an insured would never be legally liable under general principles of tort law -- those damages that are not objectively foreseeable. Thus, although the court expressly disapproved those cases relying on an objective viewpoint test for defining "accident," it neither implied nor expressed any intention to undermine or fundamentally alter the established general nature of CGL policies and the risks that they were meant to cover. See, e.g., Woodfin Equities Corp. v. Harford Mut. Ins. Co., 678 A.2d 116, 128 (Md. App. 1996) (stating that "CGL policy coverage com- pensates for physical damage to the property of others, and not for an insured's contractual liability because the product or completed work supplied by the insured is not that for which the damaged third party

3 bargained" (citation omitted)), overruled on procedural grounds by 687 A.2d 652 (Md. 1997); Century I Joint Venture v. United States Fidelity & Guar. Co., 493 A.2d 370, 375 (Md. App. 1985) (explain- ing that in a CGL policy "[t]he risk intended to be insured is the pos- sibility that the goods, products or work of the insured, once relinquished or completed, will cause bodily injury or damage to property other than to the product or completed work itself . . ." (internal quotation marks and citation omitted)); see also Robert Franco, Insurance Coverage for Faulty Workmanship Claims Under Commercial General Liability Policies, 30 Tort & Ins. L.J. 785, 785- 87 (1995) (observing that because poor performance is merely a cost of doing business, it falls outside the scope of CGL coverage, which "does not serve as a performance bond, nor does it serve as a warranty of goods and services"). Thus, a CGL policy compensates for tort lia- bility for damage to the property of others and not for the insured's contractual liability. If the court in Sheets had intended to effect a rev- olution in the generally accepted understanding of CGL policies, it surely would have been more explicit than simply holding that the test for defining accident is a subjective one, as opposed to an objective one.

We believe that the proper interpretation of Sheets is revealed by the Maryland Court of Special Appeals' subsequent decision in Lerner, which interpreted Sheets. In Lerner, the court considered losses occasioned by faulty workmanship and concluded that such losses were not the result of an "accident" as used in the CGL policy. The court observed:

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Related

Woodfin Equities Corp. v. Harford Mutual Insurance
678 A.2d 116 (Court of Special Appeals of Maryland, 1996)
Sheets v. Brethren Mutual Insurance
679 A.2d 540 (Court of Appeals of Maryland, 1996)
Century I Joint Venture v. United States Fidelity & Guaranty Co.
493 A.2d 370 (Court of Special Appeals of Maryland, 1985)
Lerner Corp. v. Assurance Co. of America
707 A.2d 906 (Court of Special Appeals of Maryland, 1998)
Harford Mutual Insurance v. Woodfin Equities Corp.
687 A.2d 652 (Court of Appeals of Maryland, 1997)
United States Fire Insurance v. Milton Co.
35 F. Supp. 2d 83 (District of Columbia, 1998)

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