In Goodwill Industries of Central Oklahoma v. Philadelphia Indemnity Insurance Co., — F.4th –, 2021 U.S. App. LEXIS 37802 (Dec.
Tenth Circuit: Government COVID Closure Orders Do Not Trigger Coverage for Loss of Business Income
In a recent case, the Tenth Circuit joined other circuits in holding that government closure orders due to the COVID-19 pandemic do not trigger insurance coverage for loss of business income, reasoning that the temporary inability to use property caused by COVID shutdown orders doesn't involve a covered physical loss of property.

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