State common law claims arising from fossil fuel companies' operations which harmed the environment were largely preempted by the Clean Air Act, which regulated the use of fossil fuels and emissions standards.

Superior court erred in finding fraudulent transfer claims filed by a bankruptcy litigation trust to be derivative and falling under the definition of a "securities" claim in a corporate insurance policy where such claims only benefitted creditors rather than the company and thus were direct in nature.

In the Matter of Investigator John Kesel v. Jeffrey Holtz