When events cause people and businesses to suffer serious and costly losses and insurance benefits become critically important to recovery, United Policyholders provides guidance, advocacy support and information to facilitate fair claim payouts. Our goal is to help every person and entity that has invested in buying insurance get the full value of that investment and recover all benefits owed after adversity has struck.
Official shutdown and shelter-in-place orders due to the COVID-19 pandemic have caused crippling financial losses for businesses throughout the nation. Insurance benefits will make or break many businesses' ability to resume operations and recover. United Policyholders established this library just as we would after a hurricane or wildfire to assist the flow of desperately needed insurance funds. We thank and acknowledge our sponsors, donors and volunteers for sharing our dedication and service to empowering the insured.
In this library you will find current information, strategies and help resources for collecting all available insurance benefits for losses associated with COVID-19. The library is curated by our not-for-profit organization and a team of leading policyholder attorneys and professionals from across the United States. It features basic as well as in-depth guidance on insurance coverage, claim and legal matters plus the latest developments in the battle for coverage.
Media inquiries please email media@uphelp.org.
Last Update: 7/23/20
LOSS RECOVERY AND INSURANCE GUIDANCE ⌄
- Can businesses rely on insurance to overcome COVID-19 losses? (Bach Talk - March 19, 2020)
- Business Insurance and COVID-19 losses (4/1/2020)
- Getting (Back To) Business Interruption Insurance
PUBLICATIONS BY UP SPONSORS
Anderson Kill
Covington
Gauthier Murphy & Houghtaling, LLC
Hunton Andrews Kurth
- Coronavirus Resource Center
- Letter to the Editor Re: "SARS, Insurers Changed Policies Covering Businesses"
- Hunton Andrews Kurth LLP: Coronavirus (COVID-19) Insurance Coverage Materials
- COVID-19 Complaint Tracker
Merlin Law Group
Reed Smith
Rutter & Russin, LLC
Government Orders/Notices ⌄
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NAIC - National Association of Insurance Commissioners
COVID-19 Property/Casualty Data Call -
FEMA
Coronavirus (COVID-19) Pandemic: Eligible Emergency Protective Measures (March 19, 2020) -
Eversheds Sutherland
COVID-19 -related insurance regulatory developments
- List of State Executive Orders (Covid-19 Resources for State Leaders)
Faegre Drinker Biddle & Reath LLP
California
- Commissioner Lara Orders Insurance Data on Business Interruption Coverage to Assist Small Businesses
- FAQ on business interruption insurance and other issues affecting California small businesses
- Requirement to Accept, Forward, Acknowledge, and Fairly Investigate All Business Interuption Insurance Claims Cuased by the COVID-19 Pandemic
- COVID-19 Protection for Policyholders from Unfair Settlement Practices
Colorado
- Amending and Extending Executive Order D 2020 017 Ordering Coloradans to Stay at Home Due to the Presence of COVID-19
- Bulletin No. B-5.38: Actions to Protect Consumers with Property and Casualty Insurance Policies During the COVID-19 Public Health Emergency in Colorado
Illinios
Indiana
Maryland
Oregon
Sonoma County, CA
Broward County, FL
Pinellas County, FL
New Orleans, LA
Albuquerque, NM
New York City, NY
Dallas County, TX
Duncanville, TX
Lawsuits ⌄
United States Judicial Panel on Multidistrict Litigation
ALABAMA
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Circuit Court of Jefferson County, Alabama Tenth Judicial Circuit
COMPLAINT (Sharecroopper LLC v. Farmers Insurance Exchange) -
United States District Court for the Northern District of Alabama Western Division
COMPLAINT FOR DECLARATORY JUDGMENT (Wagner Shoes, LLC v. Auto-Owners Insurance Company)
- COMPLAINT FOR DECLARATORY RELIEF (Scratch Restaurants v. Farmers Group Inc.)
- COMPLAINT FOR DECLARATORY RELIEF (10E, LLC v. The Travelers Indemnity Company of Connecticut)
- COMPLAINT FOR DECLARATORY RELIEF (2420 Honolulu Avenue, LLC v. The Travelers Indemnity Company of Connecticut)
- COMPLAINT FOR DECLARATORY RELIEF (837 Foothill Blvd., LLC v. The Travelers Indemnity Company of Connecticut)
- COMPLAINT FOR DECLARATORY RELIEF (Mark J. Geragos v. The Travelers Indemnity Company of Connecticut)
- COMPLAINT FOR DECLARATORY RELIEF (Geragos & Geragos, APC v. The Travelers Indemnity Company of Connecticut)
- COMPLAINT (The Madera group, LLC v. Mitsui Sumitomo Ins. USA Inc.)
California more ⌄
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United States District Court Central District of California
COMPLAINT FOR DECLARATORY JUDGMENTS AND DEMAND FOR JURY TRIAL (Travelers v. geragos)
COMPLAINT AND DEMAND FOR JURY TRIAL (In-n-out Burgers v. Zurich American Insurance Co.) - Defendant Travelers Casualty Insurance Company of America's Memorandum of Points and Authorities in Support of Motion to Dismiss (Geragos & Geragos Fine Arts Building, LLC v. The Travelers Indemnity Company of Connecticut)
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United States District Court Central District of California Western Division
CLASS ACTION COMPLAINT for: (1) Breach of Contract; and (2) Declaratory Judgment (Caribe Restaurant & Nightclub, Inc. v. Topa Insurance Co.) -
Superior Court of California - County of Napa
COMPLAINT FOR DECLARATORY RELIEF (French Laundry vs. Hartford) -
Superior Court of the State of California County of San Francisco
COMPLAINT FOR DAMAGES, DECLARATORY RELIEF, AND INJUNCTIVE RELIEF (John's Grill v. The Hartford Financial Services Group)
Complaint and Demand for Jury Trial(New Restaurant Group LP v. Farmers Group Inc.) -
Superior Court of the State of California for the County of Santa Barbara
COMPLAINT & JURY DEMAND (Moda LLC v. Hartford Fire Ins. Co.) -
United States District Court for the Southern District of California
Complaint for (1) Declaratory Relief; (2) Breach of Contract; and (3) Breach of the Covenant of Good Faith and Fair Dealing (FlorExpo LLC v. Travelers Property Casualty Co. of America)
DISTRICT OF COLUMBIA
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Superior Court of the District of Columbia Civil Division
COMPLAINT (Proper Ventures, LLC v. Seneca Insurance Co. Inc.)
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United States District Court Middle District of Florida Tampa Division
COMPLAINT AND DEMAND FOR JURY TRIAL (Prime Time Sports Bar v. Certain Underwriters at Lloyd's London)- Motion to Dismiss Pursuant to Rule 12(b)(6) (Prime Time Sports Bar v. DTW1991 Underwriting Limited, A Certain Interested Underwriter at Lloyd's London)
- Plaintiff's Response to Defendant's Motion to Dismiss (Prime Time Sports Bar v. DTW1991 Underwriting Limited, A Certain Interested Underwriter at Lloyd's London)
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United States District Court Southern District of Florida
CLASS ACTION JURY DEMAND (El Novillo Restaurant v. Certain Underwriters at Lloyd's London)- Defendants Certain Underwriters At Lloyd's, London Motion to Dismiss The Complaint and Incorporated Memorandum of Law (El Novillo Restaurant v. Certain Underwriters at Lloyd's London)
- First Amended Class Action Complaint (El Novillo Restaurant v. Certain Underwriters at Lloyd's London)
- Defendants Certain Underwriters at Lloyd's, London Motion to Dismiss Plaintiffs' First Amended Class Action Comaplint and Incoroporated Memorandum of Law (El Novillo Restaurant v. Certain Underwriters at Lloyd's London)
CLASS ACTION COMPLAINT (ATMA Beauty, Inc. v. HDI Global Specialty SE)
ILLINOIS ⌄
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United States District Court for the Northern District of Illinois Eastern Division
COMPLAINT (Big Onion Tavern Group, LLC, et al v. Society Insurance, Inc.)- Society Insurance's Response in Opposition to JD1455 Inc's Motion to Reassign Cases as Related
- Memorandum of Law In Support of Defendant Society Insurance's Motion to Dismiss Under Rule 12(b)(6) or in the alternative for Summary Judgment (Big Onion Tavern Group, LLC, et al v. Society Insurance, Inc.)
COMPLAINT (Billy Goat Tavern I, Inc., et al v. Society Insurance)
- Defendant Society Insurance's Motion For Summary Judgment (Billy Goat Tavern 1, Inc., et al v. Society Insurance)
- Plaitiffs' Response in Opposition to Defendant's Motion for Summary Judgment (Billy Goat Tavern 1, Inc., et al v. Society Insurance)
COMPLAINT (Sandy Point Dental PC v. The Cincinnati Insurance Co.)
Defendant Society Insurance's Motion to Dismiss Under Rule 12(b)(6) or in the Alternative for Summary Judgmnet (Biscuit Cafe, Inc. v. Society Insurance, Inc.) -
Circuit Court of CooDefendant Society Insurance's Motion to Dismiss Under Rule 12(b)(6) or in the Alternative for Summary Judgmnet (Biscuit Cafe, Inc. v. Society Insurance, Inc.) County, Illinios County Department, Chancery Division
COMPLAINT AND REQUEST FOR DECLARATORY RELIEF (Maillard Tavern, LLC v. Socierty Insurance, Inc.) -
United States District Court for the Northern District of Illionois Eastern Division
COMPLAINT AT LAW (Siren Salon, Inc. v. Liberty Mutual Insurance Co.)
INDIANA
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Indiana Commercial Court - State of Indiana in the Marion County Superior Court
Complaint for Declaratory Judgment (Indiana Repertory Theatre, Inc. v. The Cincinnati Casualty Company)
LOUISIANA
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Civil District Court for the Parish of Orleans State of Louisiana
PETITION FOR DECLARATORY JUDGMENT (Oceana Grill v. Lloyds)
MICHIGAN
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United States District Court Eastern District of Michigan
Class Action Complaint (Turek Enterprises, Inc. v. State Farm Mutual Automobile Insurance)
NEW JERSEY
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United States District Court District of New Jersey
COMPLAINT AND DEMAND FOR JURY TRIAL (Truhaven Enterprises, Inc. v. Chubb Ltd)
COMPLAINT (Cedar Run Orthodontics, P.A. v. Hartford Financial Services Group)
COMPLAINT (7th Inning Strech LLC v. Arch Insurance Co.)
NEW YORK
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United States District Court For the Southern District of New York
CLASS ACTION COMPLAINT (Gio Pizzeria & Bar Hospitality, LLC v. Certain Underwriters at Lloyds)
Complaint and Jury Trial Demanded (Thor Equities, LLC v. Factory Mutual Insurance Co.)
Notice of Appeal (Social Life Magazine, Inc. v. Sentinal Insurance Co.)
Class Action Complaint and Demand for Jury Trial (Siegel & Siegel, P.C. v. Hartford Casualty Insurance Co.)
NEVADA
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United States District Court District of Nevada
COMPLAINT (Treasure Island v. Affiliated Insurance Co.)
CLASS ACTION COMPLAINT (Egg and I, LLC v. U.S. Specialty Insurance Co.)- Defendant's Motion to Dismiss Complaint (Egg and I, LLC v. U.S. Specialty Insurance Co.)
- Plaintiff's Opposition to Motion To Dismiss Complaint
COMPLAINT (Circus Circus LV, LP. v. AIG Specialty Insurance Co.)
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United States District Court for the Northern District of Ohio
CLASS ACTION COMPLAINT (Bridal Expressions LLC v. Owners Insurance Co.) -
United States District Court for the Southern District of Ohio
Defendant Cincinnati Insurance Company's Motion to Certify Questions to the Supreme Court of Ohio (Troy Stacy Enterprises Inc. v. The Cincinnati Insurance Co.)- Defendant the Cincinnati Insurance Company's Memorandum in Support of its Motion to Dismiss (Troy Stacy Enterprises Inc. v. The Cincinnati Insurance Co.)
- Memorandum of Law in Support of Plaintiffs' Motion for a Temporary Stay (Troy Stacy Enterprises Inc. v. The Cincinnati Insurance Co.)
Complaint (Dakota Girls, LLC v. Philadelphia Indemnity Insurance Company)
OKLAHOMA
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District Court of Pontotoc County State of Oklahoma
PETITION FOR DECLARATORY JUDGMENT (Chickasaw Nation Department of Commerce v. Lexington Ins. Co., et al) -
District Court of Bryan County State of Oklahoma
PETITION FOR DECLARATORY JUDGMENT (Choctaw Nation of Oklahoma v. Lexington Ins. Co., et al)
OREGON
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United States District Court for the District of Oregon Portland Division
CLASS ACTION ALLEGATION COMPLAINT (Dakota Ventures, LLC v. Oregon Mutual Ins. Co.)
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Court of Common Pleas of Allegheny County, Pennsylvania
COMPLAINT SEEKING DECLARATORY, COMPENSATORY AND INJUNCTIVE RELIEF (Tambellini v. Erie Insurance Exchange) - Complaint seeking Declaratoy Relief (Dianoia's Eatery, LLC v. Motorists Mutual Insurance Co.)
- Complaint seeking declaratory Relief (The Cocorico Corp. v. Motorists Commercial Mutual Insurance Company)
- Complaint seeking declaratory Relief (Umami Pittsburgh v. Motorists Commercial Mutual Insurance Company)
- Class Action Complaint (King Cobra Group v. Motorists Commercial Mutual Insurance Co.)
- Civil Action Complaint (Magna legal Services, LLC v. Hartford Fire Insurance Co.)
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United States District Court for Eastern District of Pennsylvania
Plaintiffs' Original Complaint - MiLB (Chattanooga Professional Baseball LLC, et al v. Philadelphia Indemnity Insurance Co., et al)
COMPLAINT & JURY TRIAL DEMAND (LH Dining LLC v. Admiral Indemnity Co.)
COMPLAINT - JURY TRIAL DEMANDED (C.A. Spalding Co. v. Selective Insurance Group, Inc.)COMPLAINT JURY TRIAL DEMANDED (Newchops Restaurant Comcast LLC v. Admiral Indemnity Co)
CLASS ACTION COMPLAINT(Milkboy Center City LLC v. The Cincinnati Insurance Co.)
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Supreme Court of Pennsylvania Middle District
OPINION (Friends of Devito, et al v. Tom Wolf, Governor, et al)
- United States District Court Middle District of Pennsylvania
- Class Action Complaint (Richard Kahn and AARK Enterprise LLC v. Pennsylvania National Mutual Casualty Insurance Co.)
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Court of Common Pleas Philadelphia County, Pennsylvania
Complaint for Damages and Declaratory Relief (Spector Gadon Rosen Vinci P.C. v. Valley Forge Insurance Company)
Complaint for Declaratory Judgment (Walnut Ace, LLC v. Seneca Insurance Co.) - Complaint for Declaratory Judgmnet Relief (Ian McCabe Studio, LLC v. Erie Insurance Exchange)
- Complaint for Declaratory Judgment, Breach of Contract and Statutroy Bad Faith (The Marathon Grill, Inc. v. State Automobile Mutual Insurance Company)
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United States District Court for the Western District of Pennsylvania
Class Action Complaint (1 S.A.N.T., Inc. v. Berkshire Hathaway, Inc.)
Class Action Complaint (Windber Hospital v. Travelers Property Casualty Co.)
RHODE ISLAND
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Providence/Brostol County Superior Court
Plaintiffs' Original Complaint (Clutch City Sports & Entertainment, L.P. v. Affiliated FM Insurance Co.)
TEXAS
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United States District Court for the Northern District of Texas
CLASS ACTION COMPLAINT (Christie Jo Berkseth-Rojas DDS v. Aspen American Insurance Co.) -
United States District Court for the Southern District of Texas Houston Division
COMPLAINT (SCGM v. Certain Underwriters at Lloyd's) -
District Court of Bexar County, Texas
PLAINTIFFS' ORIGINAL PETITION (Outlaws & Gents Grooming, LLC v. State Farm Lloyds) -
District Court of Dallas County, Texas
Original Petition & Request for Disclosure (Vandelay Hospitality Group LP v. The Cincinnati Insurance Company)
WASHINGTON
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Superior Court of the State of Washington for the Couty of King
COMPLAINT (Seattle Gymnastics Academy, Inc. v. Sentinel Insurance Co.)
COMPLAINT (Aspen Lodging Group LLP v. Affiliated FM Insurance Co.) -
United States District Court for the Western District of Washington at Seattle
Motion to Strike and Dismiss all Class Action Allegations in Plaintiff's Complaint (Germack DDS v. The Dentists Insurance Co.)
COMPLAINT - CLASS ACTION (NUE LLC v. Oregon Mutual Insurance Company)
WISCONSIN
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United States District Court for the Eastern District of Wisconsin
CLASS ACTION COMPLAINT (Rising Dough, Inc. v. Society Insurance)
INFOGRAM
INTERNATIONAL
-
Commercial Court of Paris
AXA Paris Opinion (English Translation)- AXA Paris Opinion (Original)
Legislation ⌄
- To make available insurance coverage for business interruption losses die to viral pandemics, forced closures of businesses, mandatory evacutations, and public safety power shut-offs, and for other purposes (HR 6494)
- To make available insurance coverage for business interruption losses due to national emergencies, and for other purposes.
- To establish a Pandemic Risk Reinsurance Program, and for other purposes (PRIA)
Nationwide Updates
California
Louisiana
- INSURANCE: Provides relative to business interruption claims due to the coronavirus disease 2019 pandemic (HB 858)
- INSURANCE POLICIES. Provides relative to business interuption insurance (SB 477)
- INSURANCE POLICIES. Creates the BUsiness Compensation Fund (SB 495)
- 2020 LA SCR 65
- 2020 MS S 2772
Massachusetts
Michigan
New Jersey
New York
- Requires certain perils to be covered under business interuption (A10226)
- AN ACT in relation to requiring certain perils be covered under business interruption insurance during the coronavirus disease 2019 (COVID-19) pandemic
- AN ACT in relation to requiring certain perils be covered under business interruption insurance policies issued to certain human services and community-based health providers during the coronavirus disease 2019 (A10327)
Ohio
Pennsylvania
- Providing for insurance coverage for business interruption (HB2372)
- Providing for COVID-19 disaster emergency business interuption grants (PA H 2386)
- Providing for business interruption insurance assistance and for powers and duties of the Department of Community and Economic Development (PA H 2386 - Amended)
Rhode Island
South Carolina
RELATED INFORMATION ⌄
Barnes & Thornburg LLP
Bramnick, Rodriguez, Grabas, Arnold & Mangan
Farella Braun + Martel LLP
Fey Consulting
Goldberg Segalla
Greenberg Glusker
Insurance Journal
Jenner & Block LLP
Limandri & Jonna LLP
Lisa Miller & Associates
McCarter & English
McGuireWoods
McKool Smith
- How to Maximize Insurance Coverage For Coronavirus Issues
- Availability of Insurance Coverage for Immediate Coronavirus Losses
Miller Friel
Multistate
Newmeyer Dillion
Pasich LLP
- Legal Alert – Insurance Coverage for Losses and Claims Associated with the Coronavirus
- Commissioner outlines insurers' duties during the pandemic
Perkins Coie
- Coronavirus (COVID-19): Guidance for Businesses
- Coronavirus Coverage: How to Offset Your Business Losses in a Global Health Emergency
- Coronavirus Coverage: Policy Language that May Cover (or Exclude) Your Business Interruption Losses Caused by the Outbreak
- UK COVID-19 Business Interruption Disputes Process May Offer Guidance to US Policyholders
Pillsbury Winthrop Shaw Pittman LLP
Plews Shadley Racher & Braun Attorneys at Law
Saul Ewing Arnstein & Lehr LLP
Saxe Doernberger & Vita, P.C.
- Covid-19 Insurance coverage resources (library)
Schwartz, Conroy & Hack, PC
- Coronavirus Insurance Coverage Battles Begin
- Will Your Business Interruption Insurance Cover You For Coronavirus Losses?
Spilman Thomas & Battle
Tyson & Mendes
Univeristy of Minnesota Law School
Westmont Associates, Inc.
White and Williams, LLP
William Fry (Ireland, United Kingdom)
SCIENTIFIC RESEARCH ⌄
Elsevier
EPA
International Journal of Environmental Research and Public Health
National Center for Biotechnology Information
The National Law Review
The New England Journal of Medicine
Society for Risk Analysis
Tulane University
World Journal of Clinical Cases
OTHER ⌄
- Travelers' Rate Filing Exclusion of Loss Due to Virus or Bacteria (California Department of Insurance )
- 2006 ISO memo explaining template virus exclusion
- American Association of Insurance Services - Virus Or Bacteria Exclusion
- Business Interruption Group - A Nonprofit
- SBA Disaster Assistance in Response to the Coronavirus
- Report Card to Date on the $6.5 Billion+ Promised To Auto Insurance Customers as People Drive Less Due To COVID-19 (Consumer Federation of America)
- Proposed Virus Coverage Backstop Leaves Pricing in the Air (Law 360)
- Triple-I Update Economic Briefing (Insurance Information Institute )
- Contagion Event Endorsement (Tokio Marine HCC)
- Pandemic Event Endorsement(Tokio Marine HCC)
- Denial Letter (Nationwide)
- AXA vows to pay COVID-19 claims after French court battle (Property Casualty 360 )
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