United States Fire Insurance Company v. Peterson's Oil Service, Inc.

CourtCourt of Appeals for the First Circuit
DecidedSeptember 9, 2025
Docket24-1671
StatusPublished

This text of United States Fire Insurance Company v. Peterson's Oil Service, Inc. (United States Fire Insurance Company v. Peterson's Oil Service, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States Fire Insurance Company v. Peterson's Oil Service, Inc., (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1671

UNITED STATES FIRE INSURANCE COMPANY and THE NORTH RIVER INSURANCE COMPANY,

Plaintiffs, Appellants,

v.

PETERSON'S OIL SERVICE, INC., d/b/a CLEGHORN OIL BY PETERSON and d/b/a PETERSON OIL; HOWARD WOOD PETERSON, JR., KRISTEN PETERSON HALUS; SHARON PETERSON; SHEENA MARANDINO; SEAN MARANDINO; NANCY CARRIGAN; CLAIRE FREDA; KELLEY FREDA; ALICE HART; ROBERT F. HART; TORRE MASTROIANNI; and CONGREGATION BETH ISRAEL OF WORCESTER,

Defendants, Appellees.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Denise J. Casper, U.S. District Judge]

Before

Montecalvo, Lipez, and Aframe, Circuit Judges.

Kristin V. Gallagher, with whom Frank M. Falcone, Joanna L. Young, Kennedys CMK LLP, Joan A. Lukey, and Manatt, Phelps & Phillips, LLP were on brief, for appellants.

Louis M. Ciavarra, with whom AiVi Nguyen, Jared A. Fiore, Brian J. Edmonds, and Prince Lobel Tye LLP were on brief for appellees, Peterson's Oil Service, Inc., Howard Wood Peterson, Jr., Kristen Peterson Halus, and Sharon Peterson. Jeffrey S. Strom, with whom John Regan, Regan Strom, P.C., Edward Foye, and Arrowood LLP were on brief, for appellees Sheena Marandino, Sean Marandino, Nancy Carrigan, Claire Freda, Kelley Freda, Alice Hart, Robert F. Hart, Torre Mastroianni, and Congregation Beth Israel of Worcester.

September 9, 2025 AFRAME, Circuit Judge. This appeal concerns a dispute

over whether United States Fire Insurance Company and The North

River Insurance Company (together, the "Insurers") must defend

their insured, Peterson's Oil Service, Inc., against a class action

lawsuit brought by its customers concerning Peterson's sale of

heating fuel blended with high amounts of biodiesel. After

initially defending Peterson's in the litigation subject to a

reservation of rights, the Insurers filed this action in the U.S.

District Court for the District of Massachusetts seeking a judgment

declaring that they have no defense or indemnity obligations under

the relevant general liability insurance policies. In ruling on

the Insurers' motion for summary judgment, the district court

rejected the Insurers' argument that Peterson's intentional

decision to alter the chemical composition of its heating oil

removed the underlying action from the scope of coverage, ruled

that the policies' failure-to-supply limitations did not apply,

and ordered the Insurers to continue defending Peterson's in the

pending litigation. We affirm.

BACKGROUND

A. The Underlying Litigation

This coverage dispute arises out of a Massachusetts

state court class action brought against Peterson's and three of

its officers (collectively, "Peterson's") by a putative class of

customers (the "customer-plaintiffs") who say that, for years,

- 3 - Peterson's supplied them with a biodiesel-blended fuel product

that was incompatible with conventional heating systems and less

efficient than the ordinary heating oil that they believed they

had purchased. Per the operative complaint,1 every gallon of fuel

that Peterson's supplied between 2012 and 2019 consisted of more

than five percent biodiesel -- the maximum amount of biodiesel a

fuel blend may contain while still qualifying as ordinary heating

oil under relevant industry standards -- and contained an average

of thirty-five percent biodiesel between 2015 and 2018. Peterson's

allegedly continued to distribute blended fuel even after

receiving numerous complaints from customers reporting heating

system failures in 2018, and only early in 2019 began disclosing

the high level of biodiesel in its products. As a result, the

customer-plaintiffs assert that they paid more for Peterson's fuel

than it was worth, suffered repeated losses of heat, and incurred

permanent damage to their heating systems.

The customer-plaintiffs brought five claims against

Peterson's under Massachusetts law. The causes of action include

a breach-of-contract claim arising out of Peterson's failure to

supply customers with the ordinary heating oil that it had agreed

to deliver, a fraud claim for misrepresentations and omissions

1 The district court based its summary judgment ruling on the allegations set forth in the Fifth Amended Complaint. Although this pleading has since been amended, the parties agree that the changes are immaterial to the issues on appeal.

- 4 - made by Peterson's concerning the quality and suitability of its

fuel, and a negligence claim based on, among other things,

Peterson's failure to exercise reasonable care in delivering

heating oil that would efficiently heat customers' homes and not

damage their heating equipment

B. The Policies

Between July 1, 2011 and July 1, 2016, Peterson's

maintained five successive one-year commercial general liability

policies (the "primary policies") issued by the Insurers. Each

primary policy provided coverage for "those sums that the insured

becomes legally obligated to pay as damages because of

. . . 'property damage' to which this insurance applies," so long

as the damage was caused by an "occurrence" and took place during

the policy period.

The primary policies define "occurrence" to mean "an

accident, including continuous or repeated exposure to

substantially the same general harmful conditions." "Property

damage," in turn, means "physical injury to tangible property,

including all resulting loss of use of that property" or "[l]oss

of use of tangible property that is not physically injured." Each

primary policy contains a $1 million per occurrence limit and a $2

million general aggregate limit. These limits are subject to

various conditions, including a "Failure to Supply" endorsement

that limits coverage for "property damage arising out of the

- 5 - failure of any Insured to adequately supply gas, oil, water,

electricity or steam" to $250,000 in each policy year.

Peterson's was also covered under five corresponding

umbrella liability policies issued by The North River Insurance

Company between July 2011 and July 2016. The umbrella policies

provide coverage in the amount of $15,000,000 per occurrence and

in the aggregate, subject to certain conditions and exclusions.

Like the primary policies, the umbrella policies define

"occurrence" to mean "an accident, including continuous or

repeated exposure to substantially the same general harmful

conditions that results in . . . '[p]roperty [d]amage' that is not

expected or intended by the [i]nsured."

The umbrella policies in effect between July 2011 and

July 2015 exclude coverage entirely for property damage arising

out of Peterson's failure to "adequately supply gas, oil, water,

electricity or steam." The umbrella policies in effect between

July 2014 and July 2016 also contain a similar overlapping

exclusion for property damage arising out of Peterson's failure

"to provide an adequate supply of gas, oil, electricity, steam, or

any other form of energy, or water, to any person or entity."2

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United States Fire Insurance Company v. Peterson's Oil Service, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-fire-insurance-company-v-petersons-oil-service-inc-ca1-2025.