Pristine Pools LLC v. Hartford Fire Insurance Co

CourtCourt of Appeals for the Third Circuit
DecidedJune 2, 2026
Docket25-1679
StatusUnpublished

This text of Pristine Pools LLC v. Hartford Fire Insurance Co (Pristine Pools LLC v. Hartford Fire Insurance Co) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pristine Pools LLC v. Hartford Fire Insurance Co, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 25-1679 ____________

PRISTINE POOLS, LLC; JONATHAN MEHALIC,

Appellants

v.

HARTFORD FIRE INSURANCE COMPANY; HARTFORD CASUALTY INSURANCE COMPANY ____________

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. Civil No. 2:24-cv-00269) Chief District Judge: Honorable Cathy Bissoon ____________

Argued on March 12, 2026

Before: Krause, Mascott, and Fisher, Circuit Judges.

(Filed: June 2, 2026)

Edward I. Levicoff ARGUED The Levicoff Law Firm 4 PPG Place, Suite 200 Pittsburgh, PA 15222 Counsel for Appellant

Thomas N. Brown Michael R. Carlson Ronald P. Schiller ARGUED Hangley Aronchick Segal Pudlin & Schiller One Logan Square 18th & Cherry Streets, 27th Floor Philadelphia, PA 19103 Counsel for Appellee

____________

OPINION* ____________

FISHER, Circuit Judge.

Pristine Pools, LLC, constructed an in-ground pool at an apartment complex.

Unfortunately, the completed pool could not fulfill its primary purpose: holding water.

The apartment complex sued Pristine Pools for breach of contract, breach of warranty,

and negligence, claiming damages for the expense of replacing the leaky pool and

additionally alleging that the pool caused damage to unidentified “surrounding

property.”1 Pristine Pools tendered the claims to its commercial general liability (CGL)

insurance providers, Hartford Fire Insurance Company and Hartford Casualty Insurance

Company. After Hartford denied it had a duty to defend Pristine Pools in the underlying

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. 1 App. 177–78.

2 litigation, Pristine Pools sued Hartford. The District Court granted Hartford summary

judgment. Pristine Pools appeals. We will affirm.2

To determine whether an insurer has a duty to defend under Pennsylvania law, we

first examine the policy’s terms, “which are a manifestation of the ‘intent of the

parties.’”3 Here, the policy covers a claim for property damage “caused by an

‘occurrence.’”4 An occurrence is “an accident, including continuous or repeated exposure

to substantially the same general harmful conditions.”5 This definition of occurrence,

which is common in CGL policies, is known as the “Accident Definition.”6

Next, we look to “the factual allegations contained in the [underlying] complaint”

to determine whether they trigger coverage under the terms of the policy.7 Policies that

contain the Accident Definition of occurrence “provide coverage . . . if the insured work

or product actively malfunctions, causing injury to an individual or damage to another’s

2 The District Court exercised jurisdiction under 28 U.S.C. § 1332 (diversity). We exercise jurisdiction under 28 U.S.C. § 1291 (final decisions of district courts). We review a district court’s grant of summary judgment de novo. Huber v. Simon’s Agency, Inc., 84 F.4th 132, 144 (3d Cir. 2023). Because jurisdiction in this case is based in diversity, we apply Pennsylvania law. Erie R.R. Co. v. Tompkins, 304 U.S. 64, 78 (1938). 3 Nationwide Mut. Ins. v. CPB Int’l, Inc., 562 F.3d 591, 595 (3d Cir. 2009) (quoting Donegal Mut. Ins. v. Baumhammers, 938 A.2d 286, 290 (Pa. 2007)). 4 App. 71. 5 App. 90. 6 Sapa Extrusions, Inc. v. Liberty Mut. Ins., 939 F.3d 243, 253–54 (3d Cir. 2019). 7 Mut. Ben. Ins. v. Haver, 725 A.2d 743, 745 (Pa. 1999).

3 property.”8 But “[f]aulty workmanship, even when cast as a negligence claim, does not

constitute” an occurrence9 because “[t]he fortuity implied by reference to accident or

exposure is not what is commonly meant by a failure of workmanship.”10 Additionally,

“any distinction between damage to the work product alone versus damage to other

property is irrelevant so long as both foreseeably flow from faulty workmanship.”11 The

question here, then, is whether the apartment complex’s underlying complaint contains

factual allegations that amount to an active malfunction of the work product or something

else more fortuitous than a mere claim for faulty workmanship.12 It does not.

Pristine Pools argues that the District Court erred when it “determined as a matter

of law that the [underlying allegation of] damage to ‘the surrounding property’ was

necessarily non-‘accidental.’”13 But the alleged damages, even to surrounding property,

all flow clearly from faulty workmanship. For example, the apartment complex asserted

that Pristine Pools was negligent by “damaging, breaking, and/or fracturing the pool and

8 Kvaerner Metals Div. of Kvaerner U.S., Inc. v. Com. Union Ins., 908 A.2d 888, 898 (Pa. 2006) (quoting Snyder Heating v. Pa. Mfrs.’ Ass’n Ins., 715 A.2d 483, 487 (Pa. Super. Ct. 1998)) (alterations in original). 9 Specialty Surfaces Int’l, Inc. v. Cont’l Cas. Co., 609 F.3d 223, 231 (3d Cir. 2010). 10 Kvaerner, 908 A.2d at 898 (quoting McAllister v. Peerless Ins., 474 A.2d 1033, 1036 (N.H. 1984)) (alterations in original). 11 Sapa Extrusions, 939 F.3d at 256. 12 Am. & Foreign Ins. Co. v. Jerry’s Sport Ctr., Inc., 2 A.3d 526, 541 (Pa. 2010) (“The question of whether a claim against an insured is potentially covered is answered by comparing the four corners of the insurance contract to the four corners of the complaint.”). 13 Appellant’s Br. 28.

4 surrounding Property as a result of the negligent construction.”14 No claim is based on an

alleged accident or fortuitous event and, therefore, no claim amounts to an occurrence

covered under the policy.

Pristine Pools resists this straightforward application of Pennsylvania law and

argues that the District Court “paid insufficient heed to”15 two decisions by the

Pennsylvania Superior Court: Indalex Inc. v. National Union Fire Insurance Co. of

Pittsburgh16 and Pennsylvania Manufacturers Indemnity Co. v. Pottstown Industrial

14 App. 177. 15 Appellant’s Br. 39. Pristine Pools more generally argues that the District Court did not properly apply Pennsylvania law “and instead relied exclusively upon federal cases that are distinguishable.” Id. at 29. “In the absence of a controlling decision by the Pennsylvania Supreme Court, a federal court applying that state’s substantive law must predict how Pennsylvania’s highest court would decide [the] case.” Berrier v.

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Related

Erie Railroad v. Tompkins
304 U.S. 64 (Supreme Court, 1938)
Berrier v. Simplicity Manufacturing, Inc.
563 F.3d 38 (Third Circuit, 2009)
Donegal Mutual Insurance v. Baumhammers
938 A.2d 286 (Supreme Court of Pennsylvania, 2007)
Mutual Benefit Insurance v. Haver
725 A.2d 743 (Supreme Court of Pennsylvania, 1999)
Snyder Heating Co. v. Pennsylvania Manufacturers' Ass'n
715 A.2d 483 (Superior Court of Pennsylvania, 1998)
American & Foreign Insurance v. Jerry's Sport Center, Inc.
2 A.3d 526 (Supreme Court of Pennsylvania, 2010)
Sapa Extrusions Inc v. Liberty Mutual Insurance Co
939 F.3d 243 (Third Circuit, 2019)
Indalex Inc. v. National Union Fire Insurance
83 A.3d 418 (Superior Court of Pennsylvania, 2013)
City of Cleveland v. Baker
4 Ohio App. 68 (Ohio Court of Appeals, 1914)
Cline v. Martin
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Nautilus Ins. Co. v. 200 Christian St. Partners, LLC
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McAllister v. Peerless Insurance
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Jamie Huber v. Simons Agency Inc
84 F.4th 132 (Third Circuit, 2023)

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Pristine Pools LLC v. Hartford Fire Insurance Co, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pristine-pools-llc-v-hartford-fire-insurance-co-ca3-2026.