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The Insurance Coverage Law Bulletin

March 2010

Lengthy Crimes, Limited Coverage: Recent Case Law Follows the ‘One Policy Limit’ Approach

By Mary Beth Forshaw, Lynn K. Neuner and Hema V. Shenoi

The recent decisions in Madison Materials, PBSJ, and Hartman & Tyner provide further support for the majority view that coverage for a multi-year crime is limited to one policy period despite successive policies in effect during the crime.

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