National Assisted Living Risk Retention Group v. Henry Walton Bishop, III, individually and as Personal Representative of the Estate of Henry Walton Bishop, Jr.; J&S Assisted Living and Consultant LLC; Richard Marshall; and Sabrina Marshall
The First District reversed a judgment holding a claims-made insurer liable for denying coverage, holding that neither the insured's notice call reporting the underlying death and regulatory investigations nor the agencies' requests for proof of insurance constituted a 'claim' as the policy defined it. Because the only demand for damages on behalf of the decedent came in 2014 — long after the 2012 policy expired — no claim was ever made within the policy period, and the insurer owed no coverage or defense. The court also held that improper cancellation would not have changed the result, since the policy expired on its own terms in January 2013.
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