In Navigators Specialty Insurance Company v. Avertest, LLC etal, Case No. 25-1977 (4th Cir. June 9, 2026) Columbia Casualty Company (“Columbia”) provided claims-made professional liability coverage to Averhealth/Avertest, LLC (“Avertest”) through May 1, 2022. Navigators Specialty Insurance Company (“Navigators”) provided claims-made coverage from May 1, 2022 to May 1, 2023. This case centers on a dispute between the two insurance companies — Columbia and Navigators — which disagree as to which company, if either, is responsible for providing coverage for a claim againsf their insured, Avertest. Navigators provided coverage at the time of the claim but later filed suit, alleging that Columbia was legally obligated to provide coverage. Navigators argued that Columbia was responsible for coverage because the disputed claim was “related” to an earlier claim made during Columbia’s coverage period.
The District Court concluded that the relevant terms of Columbia’s policy did not require it to provide coverage for the disputed claim and instead held that Navigators was required to provide coverage. The Fourth Circuit disagreed and concluded that the disputed claim was “related” to an earlier claim that Columbia was obligated to cover. And because the two claims are related, pursuant to the terms of Columbia’s policy, it held that Columbia is obligated to cover the disputed claim as well. Therefore, the Court of Appeals vacated the trial court’s decision.
The Fourth Circuit relied upon policy language that related claims, “whenever made,” are “considered a single claim first made during the policy period in which the earliest claim was first made.” Because the policy plainly allowed for related claims coverage by treating the second claim, “whenever made,” and the first claim together as “a single claim first made during the policy period in which the earliest claim was first made” the Court reversed and remanded for entry of judgment consistent with this opinion