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Umbrella Coverage and the Definition of Insured

In Universal Underwriters Ins. Co. v. Paradis, 2008 WL 215867 (Conn., 2008), automobile dealer Crowley Chrysler-Plymouth, Inc.’s liability insurer, Universal Underwriters Insurance Company, brought an action for declaratory judgment that the dealer’s policy did not provide umbrella coverage for the dealer’s employee, Paradis; Paradis had been driving the motor vehicle in the accident that killed decedent Lamont. The Superior Court entered summary judgment in favor of Universal.

The trial court denied the motion for summary judgment filed by the administrator of Lamont’s estate and granted the plaintiff’s cross motion for summary judgment. The trial court noted that because the unicover policy explicitly named the individual insureds for each coverage part separately and Paradis was not listed as a designated person under the umbrella coverage, the definition of an insured for such coverage had a definite and precise meaning for which there was no reasonable basis for a difference of opinion. Thus, the court stated, efforts by the defendants to assert that Paradis had umbrella coverage failed.

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